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The DGT confirms that payments to a partner acting as a commercial agent are deductible provided the accounting registration, obligation arising, income correlation, and justification conditions are met, as these functions differ from those of an administrator.
Question raised 1) Whether the remuneration received by the partner-director for their work as a commercial agent in the company would constitute a tax-deductible expense for the company.
Expenses for remuneration to the partner for work performed are tax-deductible provided they comply with accounting registration, accrual-based attribution, and proper substantiation. This is applicable because such remuneration constitutes consideration for functions distinct from those inherent to the position of director. To value these transactions between related parties, the normal market value must be applied.
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