How the DGT's position has evolved
Current position
Remuneration for administrative functions constitutes income from employment unless the position is unpaid. Services provided by partners that do not meet the requirements for economic activity are classified as income from employment. The valuation of these operations must be adjusted to the normal market value. In the artistic field, the sale of works and the assignment of copyrights are classified as income from professional activities, regardless of the scarcity or irregularity of the transactions.
The DGT's position remains constant regarding the distinction between income from employment and income from economic activities, especially in the classification of administrative functions and partner services. There is a consolidation in the classification of artistic activity as professional, even in the face of sporadic income or assignments of rights. No doctrinal changes are observed, but rather a repeated application of criteria regarding market valuation and the nature of the income.
Analysis based on 18 of 19 rulings with a stated position. Updated 29 July 2026.