Doctrine by topic · DGT Observatory

Volunteering: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

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How the DGT's position has evolved

Settled doctrine High confidence 8 rulings · 2015–2021

Current position

Economic compensation for volunteering is classified as income from employment (IRPF) as it derives from the provision of personal services. The exemption for per diems under Article 9 of the Regulation is not applicable because it requires an employment or statutory relationship with elements of dependency. Taxation is only avoided if the entity directly provides means of transport or accommodation without any particular benefit to the volunteer.

The DGT's position remains constant in classifying these amounts as income from employment. The inapplicability of the per diem exemption due to the lack of an employment or statutory relationship has been systematically reiterated. The doctrine has consolidated around the distinction between the reimbursement of expenses and the direct provision of means by the entity.

Turning points

  1. V3667-15

    It established an exceptional distinction where, if the collaboration is a circumstantial event without an employment relationship, the compensation qualifies as a capital gain according to Article 33.1 of Law 35/2006.

Analysis based on 8 of 8 rulings with a stated position. Updated 1 October 2026.

Rulings on this topic

8
V2366-21 20 Aug 2021

Economic compensation for volunteers is taxed as employment income

SG de Impuestos sobre la Renta de las Personas Físicas
rendimientos del trabajovoluntariadorégimen de dietasgastos de desplazamientoretención LIRPF — Ley 35/2006 del IRPF art. 17.1LIRPF — Ley 35/2006 del IRPF art. 17.1.d
Affects CompanyExpat · Non-residentIndividual

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