How the DGT's position has evolved
Current position
The provision of courses, lectures, or seminars is taxed as income from employment, unless the taxpayer organizes the means of production or human resources on their own account. If the organization is carried out by a third party, the income does not constitute an economic activity. In this case, deductible expenses are limited exclusively to those provided for in article 19.2 of the LIRPF (Personal Income Tax Law).
The DGT's position has remained constant since 2014, maintaining the distinction between income from employment and economic activity based on the organization of means. No changes have been observed in the classification of the income, although the most recent ruling specifies the limitation of the applicable deductible expenses.
Turning points
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Specifies that, in the case of income from employment, deductible expenses are limited exclusively to those provided for in article 19.2 of the LIRPF.
Analysis based on 15 of 17 rulings with a stated position. Updated 25 September 2026.