Skip to content
Back to index
V3062-14 7 November 2014 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos de actividades económicas

Foreign spokesperson fees classified as economic activity income

A Spanish resident asks whether their services as a spokesperson for a Japanese racing team abroad are considered economic activity. The DGT determines these incomes are economic activity income and examines their subject to IAE and withholdings.

The question raised

Whether said services are considered administrative services or public relations services.

The DGT's ruling

Income derived from the provision of spokesperson services is classified as income from economic activities pursuant to Article 27.1 of the Personal Income Tax Law (LIRPF). As the activity is carried out abroad, it is not subject to the Business Activities Tax (IAE). The foreign company is not obliged to withhold Personal Income Tax (IRPF) if it is not a resident in Spain nor operates through a permanent establishment.

Book your free first meeting