International taxation

Analysis of the exemption under Article 7 p) of the Spanish Personal Income Tax Act for employment income earned abroad

Law dissertation · Complutense University of Madrid · ISDE award (2025)

A study of one of the most disputed exemptions in Spanish personal income tax: the exemption under Article 7 p) of Act 35/2006 for employment income relating to work actually carried out abroad.

The work analyses the conditions for its application, the friction points that recur in tax reviews — the reality and effectiveness of the assignment, the benefit to the non-resident entity and the documentary evidence of the work performed — and its practical relevance to the international mobility of employees.

It was awarded the 15th ISDE International Legal Award 2025 in the student category.

Sources

  • Act 35/2006 of 28 November on Personal Income Tax, Article 7 p).
  • Administrative doctrine and case law on the exemption.

How to cite this work

DÍAZ-HEREDERO LÓPEZ, G., “Analysis of the exemption under Article 7 p) of the Spanish Personal Income Tax Act for employment income earned abroad”, DÍAZ-HEREDERO Legal & Tax, 2025. Available at: https://diazheredero-web.pages.dev/en/research/article-7p-exemption-work-carried-out-abroad/ (accessed: dd/mm/aaaa).

Published content is informative in nature and does not constitute individual advice. It does not replace the analysis of a specific case or the review of the corresponding documentation.

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