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The consultant asks whether IRNR should be withheld on commission paid to an artist agency. The DGT states that if the commission is for intermediation and the agency has no permanent establishment in Spain, the income is exempt under the OECD Model Convention.
Question raised: The taxpayer asks whether the commission paid to the representation agency is subject to withholding under the Non-Resident Income Tax.
If the amounts collected by the agency are for intermediation and the agency does not carry out activities in Spain through a permanent establishment, its profits are exempt pursuant to Article 7 of the OECD Model Tax Convention. In this case, withholding tax is not applicable under Article 31.4 of the Non-Resident Income Tax Law. However, if the amounts received by the agency remunerate the artist's activity, they shall receive the same treatment as the income of the artist themselves.
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