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The applicant inquired whether they could apply for the exemption on employment income for undertaking a training programme at the European Commission while still receiving remuneration in Spain. The DGT ruled that this is not applicable because the activity is for training purposes and does not constitute employment for a non-resident entity.
Question raised Whether the exemption provided for in Article 7 p) of the Personal Income Tax Law is applicable to you.
La exención del artículo 7 p) de la LIRPF requiere que los trabajos se realicen para una entidad no residente o un establecimiento permanente en el extranjero. Para que el trabajo sea efectivo en el extranjero, debe haber desplazamiento y el centro de trabajo debe ubicarse fuera de España. Dado que la actividad de los Expertos Nacionales en Formación Profesional tiene un objetivo fundamentalmente formativo, no se considera un trabajo efectuado para la entidad destinataria a efectos de esta exención.
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