How the DGT's position has evolved
Current position
The exemption under article 7.p) of the LIRPF (Personal Income Tax Law) requires that the work be performed for a non-resident entity or a permanent establishment in a country with an analogous tax and not a tax haven. Specific remuneration and the proportional part of non-specific remuneration are exempt through an allocation based on the number of travel days relative to the total days in the year. The day count must include travel days (arrival and departure) and non-working days during the stay. The maximum exemption limit is 60,100 euros per year.
The DGT's position remains constant regarding the calculation method through proportional allocation by days. The evolution focuses on the precision of the temporal calculation, progressively integrating travel days, non-working days, and quarantine periods as part of the effective displacement. No changes have been observed in the requirements for the employing entity or in the economic limits.
Turning points
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It is established that the quarantine time imposed in the destination country counts as travel days for the calculation of the exemption.
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It is specified that for the calculation, the arrival and departure days must be specifically considered as part of the displacement.
Analysis based on 56 of 60 rulings with a stated position. Updated 15 September 2026.