How the DGT's position has evolved
Current position
The exemption under article 7.p) of the LIRPF (Personal Income Tax Law) applies to income from employment actually performed abroad for a non-resident entity or a permanent establishment abroad. The destination country must apply an analogous tax and must not be a tax haven, or must have an information exchange agreement with Spain. The exempt income includes amounts accrued during the days of stay, which also includes the days of travel to the destination country or the return to Spain.
The DGT's position remains constant regarding the requirements of territoriality and the nature of the tax in the destination country. The evolution focuses on the precision of the temporal calculation, integrating travel days into the exemption following the doctrine of the Supreme Court. No changes are observed in the applicable quantitative limits.
Turning points
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Specifies that the exemption includes the days of travel to the destination country or the return to Spain, based on the doctrine of the Supreme Court.
Analysis based on 46 of 48 rulings with a stated position. Updated 20 September 2026.