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V3070-14 11 November 2014 · SG de Fiscalidad Internacional Criterion in force
IRPF · cambio de residencia

IRPF retention for repatriated workers must be calculated on total annual earnings

A worker sent to Qatar is repatriated to Spain, becoming a fiscal resident. The question arises whether IRPF withholdings are based only on earnings paid in Spain or whether they include foreign-earned income.

The question raised

The consultant raises the following:

The DGT's ruling

To calculate IRPF withholdings following a change of residence, the company must take into account the total amount of employment income pursuant to Article 83 of the RIRPF. The withholdings applied under the Non-Resident Income Tax (IRNR) during the year of the change of residence shall be considered advance payments towards the IRPF. Regarding income earned abroad, if it is not subject to IRNR, no withholdings are applied, but it must be included in the annual withholding summary.

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