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V2786-18 24 October 2018 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos del trabajo

Federation fees cannot be deducted as professional association dues for Income Tax purposes

An athletics judge inquired whether the payment of their mandatory federation fee is deductible as an expense for Income Tax (IRPF) purposes. The Directorate General of Taxes (DGT) ruled that it is not, as sports federations are private entities rather than professional associations.

The question raised

Upon including the aforementioned remuneration as employment income in their Personal Income Tax returns, the taxpayer asks whether the payment of the federative license (mandatory to participate in competitions) is equivalent to the fees paid to professional associations for the purposes of being considered a deductible expense from gross employment income: Article 19.2.d) of Law 35/2006.

The DGT's ruling

Federative licenses do not fall within the scope of professional association fees under Article 19.2.d) of Law 35/2006. This is because professional associations are public law corporations, whereas sports federations are private entities with their own legal personality. Therefore, the license expense is not deductible under that concept.

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