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A resident in Venezuela asks whether they must pay tax in Spain for the ownership of real estate and for the commercial brokerage commissions received from Spanish companies. The DGT responds that the commissions are not taxed in Spain as they constitute international sales, but the real estate is subject to IRNR due to imputed income.
Question posed: Requests information regarding the taxation of the real estate under their ownership and whether the commissions received from Spanish clients are subject to taxation in Spain.
Mediation commissions in international sales of goods are not considered income obtained in Spanish territory, regardless of where they are collected. On the other hand, non-resident owners of urban real estate in Spain must pay IRNR for the imputed income corresponding to properties intended for personal use. To apply the Spain-Venezuela Convention, the inquirer must prove their tax residence by means of a certificate issued by the competent authority of Venezuela.
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