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A company has inquired whether the income of an employee seconded to France to perform management duties may be exempt under Article 7(p) of the Personal Income Tax Act (LIRPF). The Directorate General for Taxes (DGT) indicates that, for an exemption to apply in cases involving related parties, the work must constitute an intra-group service that provides an advantage or benefit to the non-resident entity.
Question raised: Whether the exemption provided for in letter p) of Article 7 of the Personal Income Tax Law is applicable to the income received by said worker by reason of the described work.
Para aplicar la exención, el trabajador debe ser residente fiscal en España y realizar los trabajos efectivamente en el extranjero. En casos de empresas vinculadas, el servicio debe ser una prestación intragrupo que aporte una utilidad a la entidad no residente, según el artículo 18 de la LIS. No se considera servicio intragrupo la actividad que la matriz realiza por sus propios intereses como accionista, como el seguimiento de inversiones. El país de destino no debe ser paraíso fiscal y debe tener un convenio de intercambio de información con España.
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