How the DGT's position has evolved
Current position
The withholding base is composed of the total amount of subject and non-exempt remuneration expected to be received during the year. Exempt income is not included in said base pursuant to art. 75.3.a) RIRPF. In the case of services provided in Spain, withholding must be applied to the full amount of the sums paid without applying deductions or reducing the base for social security charges.
The DGT's position remains constant in determining the withholding base as the amount of income subject to tax. The analyzed rulings address different scenarios (pensions, insurance, professional services) but maintain consistency in applying withholding to the taxable portion or the full amount depending on the nature of the income.
Analysis based on 47 of 49 rulings with a stated position. Updated 19 September 2026.