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V2476-14 23 September 2014 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · renta mundial

Course fees in Costa Rica not taxable in Spain under double taxation treaty

A Spanish resident asks whether fees from teaching a one-week course in a Costa Rican university are taxable there and whether they can claim a deduction in Spain. The DGT states that, under the double taxation treaty, income is only taxable in Spain and that the activity is not subject to Spanish VAT.

The question raised

Whether Costa Rica may tax the aforementioned fees. And, if so, whether the tax paid in Costa Rica could be deducted in Spain.

The DGT's ruling

According to the Convention between Spain and Costa Rica, the remuneration of a resident in Spain who remains temporarily in Costa Rica to teach at a university may only be taxed in Spain. Regarding VAT, training services materially provided in Costa Rica to a recipient who is an entrepreneur or professional established there are not subject to Spanish tax as they are located in Costa Rica.

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