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V2617-15 8 September 2015 · SG de Fiscalidad Internacional Criterion in force
IRPF · funciones de carácter público

Japanese public school teachers posted to Spain only tax in Japan

The DGT confirms that Japanese public school teachers receiving salaries from Japanese state funds are only liable to tax in Japan.

The question raised

Question raised: Tax regime applicable to the remuneration received by the aforementioned professors.

The DGT's ruling

According to Article 19 of the Convention between Spain and Japan, remuneration paid by a State to a natural person for public functions is taxable only in that State. Since the professors are Japanese civil servants, citizens of Japan and not Spanish, their remuneration may only be taxed in Japan. If they were of Spanish nationality, they would be taxed in Spain.

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