How the DGT's position has evolved
Current position
Income from teaching courses, lectures, or seminars is considered income from employment, unless it involves the organization on one's own account of means of production or human resources. It is classified as an economic activity if the taxpayer acts as an organizer by offering the events to the public or participating in their results. The classification depends on whether the subject assumes the organization or intervenes in the production or distribution of the services.
The DGT's position has remained stable over time. The central criterion is that the organization of means of production or human resources transforms income from employment into economic activities. Recent rulings maintain the distinction based on the capacity for organization and the assumption of risks or results.
Turning points
-
Establishes that organization on one's own account to intervene in the market qualifies the activity as economic, even if carried out on an occasional basis.
Analysis based on 52 of 54 rulings with a stated position. Updated 19 September 2026.