Skip to content
Back to index
V2613-22 23 December 2022 · SG de Fiscalidad Internacional Criterion in force
IRNR · base fija

Translation services from Thailand without a fixed establishment in Spain are taxable only in Thailand

A Thai resident asks whether she must pay Spanish tax on translation services provided remotely to Spanish clients. The DGT rules that since there is no fixed establishment in Spain, the income is taxable only in Thailand.

The DGT's ruling

According to the Spain-Thailand Convention, income from independent professional services may only be taxed in Spain if the resident has a fixed base to carry out their activity for more than 183 days in a 12-month period. The mere opening of a bank account in Spain by a non-resident does not constitute a taxable event for Non-Resident Income Tax (IRNR). If the funds in said account generate interest, these shall be governed by Article 11 of the Convention.

Book your free first meeting