On 30 September and 1 October 2013, two binding rulings were published in the Official Journal (No. 5,360 and 5,494) with respect to withholding tax on payments for services to non-residents.
In general, taxpayers subject to corporate income tax (impuesto a las rentas de las actividades económicas, IRAE) must withhold the non-residents income tax (impuesto a la renta de los no residentes, IRNR) on payments for services performed abroad. In general, the withholding tax is not deductible for corpo…