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V2833-20 22 September 2020 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · residencia fiscal

If you acquire Spanish tax residency, you must pay tax on worldwide income including both contracts

An Argentine footballer asked whether he should declare income from two separate contracts after moving to Spain. The DGT replied that, as a tax resident, he must pay tax on his worldwide income and may include IRNR withholdings as advance payments.

The question raised

Question raised: Tax residence. Whether the income from both contracts must be included in the tax return or only that from the second contract.

The DGT's ruling

Tax residence is determined by staying for more than 183 days in a calendar year or by having the core of economic activities in Spain. If these criteria are met, the taxpayer is taxed on their worldwide income under the Personal Income Tax (IRPF). Withholdings applied as a non-resident during the year of change of residence are considered advance payments of the IRPF.

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What is published here, applied to a company or a specific case. The first meeting is free.

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