Skip to content
Back to index
V2491-15 5 August 2015 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · exención

The exemption for work performed abroad cannot be applied if the activity is of a training nature

A civil servant asks whether they can apply the exemption for employment income due to having been seconded to Brussels as a national expert at the European Commission. The DGT responds that the exemption is not applicable because the activity of a national expert is fundamentally of a training nature.

The question raised

Application of the exemption provided for in Article 7 p) of the Personal Income Tax Law.

The DGT's ruling

To apply the exemption under Article 7 p) of the LIRPF, the work must be performed for a non-resident entity or a permanent establishment abroad. In the case of national experts at the Commission, the activity is fundamentally of a training nature. Therefore, it does not constitute work performed for a non-resident entity under the terms required by the regulation, and the exemption is not applicable.

Book your free first meeting