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V2393-25 9 December 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · doble imposición internacional

Effective tax amount paid abroad can be deducted without proportional calculations

A taxpayer asks whether a rule of three should be applied between foreign and Spanish bases for international double taxation relief. The DGT clarifies that the actual tax paid abroad can be deducted.

The question raised

For the purposes of applying the deduction for international double taxation, the inquiry concerns the calculation of bases and taxes abroad. Whether, to calculate the international double taxation regarding the rental of the property, the taxable base corresponding to the income tax return in the foreign country must be taken into account to perform any type of proportional calculation; specifically, whether, as the tax paid abroad instead of indicating 1,271.50 euros, the proportional part of the base subject to taxation in Spain should be included (multiplying 3,871.15 by the quotient 1,271.5 divided by 6,109.61).

The DGT's ruling

The deduction for international double taxation shall be the lesser of two amounts: the actual amount paid abroad for a tax of an identical or analogous nature to the Personal Income Tax (IRPF) or Non-Resident Income Tax (IRNR), or the result of applying the average effective tax rate to the portion of the taxable base taxed abroad. In the case presented, the actual amount of the tax paid abroad is 1,271.50 euros.

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