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V3136-19 11 November 2019 · SG de Fiscalidad Internacional Criterion in force
IRNR · hecho imponible

Opening a current account by a non-resident does not trigger IRNR tax

A non-resident entrepreneur asks whether opening a bank account in Spain to receive foreign income triggers taxes. The DGT responds that the account and transfers are tax-exempt, but interest earned may be subject to limited withholding under a double taxation treaty.

The question raised

Question posed: Taxation of income received in the Spanish current account, originating from economic activity carried out outside of Spain. Tax payable in Spain on financial income generated in the current account. Taxation if the taxpayer becomes a resident in Spain in the future.

The DGT's ruling

The mere opening of a current account or the transfer of funds from abroad does not constitute a taxable event for Non-Resident Income Tax (IRNR). The interest generated by the account may be taxed in Spain as the source State, but the Convention with Iran limits taxation to 7.5% of the gross amount. Notwithstanding, returns from non-resident accounts are exempt if legal requirements are met. If the taxpayer acquires tax residence in Spain, they shall be taxed on their worldwide income, including income from their activities abroad and the interest from the account.

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