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V2990-17 20 November 2017 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos del trabajo

A minimum withholding tax rate of 15% must be applied to professional athletes under special employment relationships

A futsal club has requested clarification on the withholding tax rate applicable to its professional players' salaries. The Directorate General for Taxes (DGT) has ruled that, as these constitute special employment relationships, the general procedure applies but with a minimum rate of 15%.

The question raised

Applicable withholding tax on employment income satisfied to its players.

The DGT's ruling

For professional athletes under a special employment relationship, withholding is determined through the general procedure set forth in Article 82 of the IRPF Regulations. Notwithstanding, the minimum rate of 15% established in Article 86.2 of the Regulations for special dependent employment relationships must be respected. If the athlete does not fall under the special employment relationship, the general procedure would apply without the 15% minimum.

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