How the DGT's position has evolved
Current position
The exemption under article 7.p) of the IRPF (Personal Income Tax) Law requires that the work be effectively performed abroad for a non-resident entity or a permanent establishment. The place of work must be outside of Spain and the destination country must apply an analogous tax or have an information exchange agreement. It is not a requirement that the income be taxed abroad. Social security contributions are deductible if they are linked to the declared work.
The position on the exemption for work performed abroad remains stable, with the DGT specifying the need for the service to produce an economic advantage for the recipient entity in cases of affiliation. Regarding scholarships, the doctrine alternates between denying exemptions due to a lack of specific requirements and confirming the exemption for researchers if the teaching status is a merit in the call for applications.
Turning points
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Clarifies that it is not necessary for the income to have been taxed abroad, provided that an information exchange agreement exists.
Analysis based on 10 of 10 rulings with a stated position. Updated 29 September 2026.