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V2192-25 17 November 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos del trabajo

Socia's remuneration for services other than administrator role deemed as earnings from work

The DGT determines that remuneration for administrative duties is earnings from work, and additional services also qualify as such due to failure to meet economic activity criteria.

The question raised

Consultation regarding the taxation under Personal Income Tax of the remuneration corresponding to the services provided by the partner to the company.

The DGT's ruling

Remuneration for administrator functions constitutes income from employment pursuant to Article 17.2.e) of the LIRPF, unless the position is unpaid. Services provided by the partner other than administration are considered income from employment under Article 17.1 of the LIRPF, as the requirements to be classified as income from economic activities under Article 27.1 are not met. The valuation of these operations must be carried out at their normal market value.

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