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V3111-19 7 November 2019 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos del trabajo

Services provided by partners to a company are deemed income from work

The DGT confirms that payments to partners for management and supervision tasks in an academy must be classified as income from work, not as economic activities, as they do not meet the criteria for economic activities.

The question raised

Question posed: Consultation regarding the Personal Income Tax (IRPF) taxation applicable to said partners for the services rendered to the company.

The DGT's ruling

The returns paid to partners for the development of the company's activities are of the nature of income from employment pursuant to Article 17.1 of the LIRPF. This is due to the fact that the requirements of the first and second paragraphs of Article 27.1 of the LIRPF are not met to be considered income from economic activities. Furthermore, the remuneration for these services must be valued at its normal market value in accordance with Article 41 of the LIRPF.

Apply this to a real case

What is published here, applied to a company or a specific case. The first meeting is free.

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