How the DGT's position has evolved
Current position
The exemption requires that the work be effectively performed abroad for a non-resident entity. In intragroup services, there must be an advantage or benefit for the recipient, implying that an independent company would pay for such activity. Activities carried out by a parent company for its own interests as a shareholder are not considered intragroup services.
The DGT's position remains constant regarding the requirements of territoriality and service utility. The evolution shows greater precision in the definition of intragroup services, clarifying that parent company activities for shareholder interests are excluded.
Turning points
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Defines the utility of the service as the willingness of an independent company to pay for the activity and excludes parent company activities for shareholder interests.
Analysis based on 76 of 78 rulings with a stated position. Updated 13 September 2026.