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An Italian citizen who worked in Spain and later moved to Belgium as a self-employed individual asks where he should pay tax on his Belgian income. The DGT determines that, having spent more than 183 days in Spain in 2014, he is a Spanish fiscal resident and must pay tax on his worldwide income.
Cuestión planteada Lugar de tributación de los rendimientos provenientes del trabajo independiente realizado en Bélgica, durante el periodo de octubre a diciembre de 2014.
Si el contribuyente es residente fiscal en España por permanecer más de 183 días en el país, tributará por su renta mundial. Los rendimientos de actividades independientes obtenidos en otro Estado solo tributarán en ese Estado si el residente dispone de una base fija allí. Si existe base fija, España permitirá la deducción de la doble imposición conforme al Convenio.
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