ES

Aspectos laborales y fiscales de los trabajadores expatriados e impatriados

Resumen: El objetivo del presente artículo consiste en analizar las cuestiones básicas a tener en cuenta en el momento de afrontar la imprescindible y estratégica gestión multinacional del capital humano, así como la posible captación de talento desde el extranjero. Esta tarea, se llevara a cabo considerando los aspectos sociolaborales y fiscales más relevantes a tener en cuenta por la empresa y el trabajador en todo momento durante la duración del desplazamiento al extranjero, así como las ventajas fiscales que a fecha de hoy otorga nuestro ordenamiento a expatriados e impatriados.

Abstract: The aim of this article is to analyse the basic questions which need to be taken into account when facing the essential, strategic multinational management of human capital as well as the search for talent abroad. This task will be carried out bearing in mind the most relevant social, labour and tax aspects which must be taken into consideration by both employer and employee while on workplacement abroad as well as the tax benefits which are to be found in our legal system to date applying to both expats and inbound expatriates.

INTRODUCCIÓN

Como consecuencia de la crisis económica que ha afectado al mundo empresarial durante los últimos años y, en concreto, la contracción del mercado doméstico, las empresas españolas se han visto en la necesidad de ampliar horizontes y probar suerte en distintos mercados internacionales, con la finalidad de diversificar sus riesgos y buscar nuevas oportunidades de negocio.

En este sentido, la economía claramente evoluciona hacia la globalización de los mercados, cuestión que algunas empresas pudieron prever en momentos anteriores al comienzo de la crisis en la que nos encontramos, habiendo apostado por su implantación en diferentes países. Sin perjuicio de lo anterior, el fenómeno de la internacionalización sigue siendo un objetivo principal para la empresa española, dirigido al relanzamiento de su competitividad para alcanzar una estructura fortalecida que les permita su continuidad en posibles situaciones económicamente complicadas.

Dentro de este contexto, el proyecto de internacionalización en las empresas conlleva una planificación exhaustiva tanto en la gestión de riesgos, la recopilación de información del mercado de destino, la adaptación en las costumbres de negocio, etc. Sin embargo, las cuestiones puramente de negocio no son las únicas que deben ser planificadas a la hora de afrontar una internacionalización, puesto que en el éxito de la misma cobra gran importancia los recursos humanos con los que cuente la empresa.

Así, en el presente artículo se procederá a analizar los puntos más importantes a tener en consideración en el momento de afrontar el desplazamiento de personas a distintos países del mundo, en el marco empresarial y personal.

ASPECTOS LABORALES Y DE SEGURIDAD SOCIAL.

PRIMERO.- Aspectos laborales.-

Como se ha mencionado con anterioridad, tanto la expatriación como la impatriación de trabajadores requieren una planificación minuciosa de los aspectos que regirán la relación laboral durante el tiempo del desplazamiento ya sea temporal o definitivo.

1.1.- Ley aplicable.-

En este sentido, una de las principales cuestiones a tener en cuenta es la ley que resulta aplicable a la relación laboral del trabajador durante el desplazamiento, debiendo diferenciar las siguientes circunstancias:

  • Si el desplazamiento implica a un país no miembro de la Unión Europea, la determinación de la ley aplicable vendrá dada por lo previsto en el Reglamento de Roma I (CE) N.º 593/2008, según el cual la ley aplicable a los contratos será la que las partes determinen, sin perjuicio del derecho del trabajador a ver respetadas las disposiciones imperativas en materia laboral que existan en el país de destino. 

En caso de no haberse elegido ley aplicable, la misma vendrá determinada por:

    • El lugar donde el trabajador preste sus servicios habitualmente, aún cuando haya sido desplazado con carácter temporal.
    • La del lugar del establecimiento del empresario que haya contratado al trabajador.
    • O bien, la del lugar en la que el contrato de trabajo tenga sus vínculos más estrechos.
  • En caso de que el desplazamiento tenga lugar entre países miembros del espacio económico europeo, la ley aplicable vendrá determinada por la Directiva 96/71/CE, sobre desplazamiento de trabajadores en el marco de una prestación trasnacional de servicios. Sin embargo, la transposición de dicha Directiva dentro de los países europeos ha implicado que, aún cuando la ley elegida por las partes no sea la del país destino, el trabajador verá garantizadas las condiciones mínimas de trabajo en vigor en el mismo.

1.2.- Normativa de inmigración en el país de destino.-

Un aspecto imprescindible a tener en cuenta a la hora afrontar la movilidad internacional de trabajadores es la normativa de inmigración en el país de destino, sobre la cual, como no puede ser de otra manera, cobra un papel importante la nacionalidad del trabajador que será desplazado y el país de destino.

En este sentido, es necesario diferenciar algunas cuestiones básicas que, salvo algunas excepciones, serán aplicables en la mayoría de los países de destino:

  • Estancias hasta 90 días: en la generalidad de los casos, las estancias no superiores a 90 días, siendo el objeto del viaje la realización de negocios, no implica la necesidad de solicitar un permiso de residencia. Sin embargo, en función de los acuerdos bilaterales o multilaterales entre el país de destino y el de la nacionalidad del trabajador, será necesario tramitar un visado de entrada o no.
  • Estancias superiores a 90 días: suele presuponer la necesidad de tramitar en el país de origen un permiso de residencia que permita, a su vez, el ejercicio de una actividad remunerada, ya sea por cuenta propia o ajena.

En conclusión, la normativa de inmigración aplicable deberá ser objeto de análisis en cada caso concreto puesto que, a diferencia de lo que sucede dentro del ámbito de la Unión Europea, no se trata de una materia unificada entre los países, siendo cada uno de ellos competentes para determinar su normativa de inmigración.

1.3.- Condiciones laborales del desplazamiento.-

Respecto a las condiciones laborales aplicables en los casos analizados, cabe mencionar que la verdadera complejidad se encuentra en la expatriación, toda vez que en las impatriaciones de trabajadores a España deberá cumplirse con la legislación laboral vigente en cada momento.

En este sentido, respecto a los trabajadores expatriados, es importante diseñar y gestionar adecuadamente el procedimiento de desplazamiento. Así, las cuestiones esenciales, en cuanto a las condiciones laborales, que deben determinarse en un contexto de movilidad internacional de un trabajador son las siguientes:

  • Vi
    nculo contractual: las posibilidades respecto a la relación laboral del trabajador pueden resumirse en las siguientes:

    • Extinción de la relación laboral con la empresa de origen y suscripción de un nuevo contrato con la empresa de destino.
    • Suspensión de la relación laboral con la empresa de origen y suscripción de un nuevo contrato con la empresa de destino.
    • Mantenimiento de la relación laboral con la empresa de origen anexando al contrato las condiciones laborales aplicables durante el tiempo de desplazamiento.

La elección entre una u otra alternativa dependerá de distintos factores que influyan en cada caso concreto, como puede ser la duración del desplazamiento, la normativa inmigratoria del país de origen, etc.

  • Temporalidad: deberá determinarse en primer lugar la necesidad empresarial sobre dicho traslado, es decir, el tiempo que será necesario que el trabajador permanezca desplazado en el extranjero:
    • Traslado de carácter permanente: en cuyo caso, lo más conveniente, probablemente sea efectuar una contratación en el país de destino.
    • Desplazamiento temporal: dentro de los cuales podrán diferenciarse los desplazamientos esporádicos de trabajadores cuyo objetivo del viaje sea la supervisión de los negocios en el país de destino, o al contrario, la expatriación de trabajadores mediante un desplazamiento cuya vocación sea temporal pero de larga duración.
  • Retribución: Dentro de este contexto, es una práctica habitual la compensación de los gastos extraordinarios que suponen a un trabajador el traslado a otro país, así como el coste personal que para el mismo supone.

Así, es común en las movilidades internacionales pactar entre las partes complementos de expatriación como pueden ser el coste de la vivienda en el país de destino, vehículo en caso de ser necesario, el coste de los viajes de vuelta al país de origen, el coste de la mudanza, entre otros.

1.4.- Resolución de conflictos.-

Otra cuestión a tener en cuentan y a la que normalmente no se atiende, en los momentos de contratación o de desplazamiento de un trabajador, es la jurisdicción competente en caso de conflictos derivados de la relación laboral.

Así, las normas que determinan la competencia territorial en los diferentes supuestos serán los Convenios de Bruselas y Lugano en el ámbito internacional y, en el ámbito de la Unión Europea, el Reglamento de Bruselas 44/2001 y la Directiva 96/71.

En este sentido, cabe hacer una breve mención a las posibilidades en cuanto a los foros aplicables en los casos de conflictos derivados de la relación laboral, diferenciando los siguientes supuestos:

  • Trabajador como parte demandante: tendrá la posibilidad de demandar
    • Ante los órganos jurisdiccionales del país en el que haya desempeñado habitualmente la prestación de servicios.
    • Ante los tribunales del último lugar en el que hubiese prestado sus servicios.
    • Ante los tribunales del país en el que el empresario estuviera domiciliado o donde estuviera situado el establecimiento de contratación.
  • Empleador como parte demandante: solamente tiene la posibilidad de ejercer una acción judicial ante el estado donde tenga el domicilio el trabajador.

SEGUNDO.- Aspectos de Seguridad Social.-

Por último, en lo que respecta a la Seguridad Social, en reglas generales el trabajador impatriado estará cubierto por la Seguridad Social española como consecuencia de la relación laboral que le une a una empresa en España.

Sin embargo, respecto a los trabajadores expatriados, la norma indica el sometimiento del trabajador a la legislación del país donde preste servicios. Sin perjuicio de la posibilidad, en los desplazamientos temporales, de mantener una situación asimilada al alta en las circunstancias previstas por el artículo 125 de la Ley General de la Seguridad Social. Así, en la generalidad de los casos en los que el desplazamiento no supere los dos años, con una posible prórroga de uno más, se podrán mantener la cotizaciones en la Seguridad Social española cuando dichos desplazamientos se realicen a países con los que España tiene suscritos contratos multilaterales o bilaterales de Seguridad Social, incluidos los desplazamientos dentro de la Unión Europea.

ASPECTOS FISCALES

Si como empresa pensamos en desplazar a alguno de nuestros trabajadores, o nos encontramos en la posición como trabajadores de ser desplazados desde España al extranjero o viceversa, sin analizar debidamente la incidencia fiscal, tanto desde la perspectiva del propio trabajador desplazado, como desde la de la empresa, debemos saber que nos faltará uno de los elementos esenciales para realizar una adecuada estimación de costes.

Este hecho, como es lógico, puede originar una serie de incertidumbres previsibles, que vendrían a sumarse a las ya intrínsecamente existentes en todo proceso de internacionalización de una empresa o a la hora de realizar un traslado de domicilio a un país extranjero por parte del trabajador.

PRIMERO.- RIESGOS SUBYACENTES A LOS DESPLAZAMIENTOS INTERNACIONALES DE TRABAJADORES.-

Una planificación fiscal previa en este sentido,[1] ayudará no solo a determinar la carga tributaria del desplazamiento, y por lo tanto acabar con las incertidumbres mencionadas anteriormente, sino que también nos servirá para prevenir una serie de riesgos que subyacen cuando se produce la expatriación de un trabajador.

Estos riesgos son distintos dependiendo desde qué prisma de la relación trabajador-empresa se lleve a cabo el correspondiente análisis, ahora bien; aunque los conceptos objeto del riesgo de una y otra parte sean diferentes, todos están íntimamente relacionados entre sí, por lo que deberá existir una coordinación perfecta entre ambas partes a lo largo del periodo de duración de la expatriación:

1.1.- Riesgos para el trabajador.-

  • Residencia fiscal: Piedra angular sobre la cual se debe estructurar cualquier tipo de planificación o previsión en este sentido, por lo quese deberá estudiar profundamente los puntos de atracción de la residenciaestablecidos en el artículo 4 del Modelo de convenio de la OCDE (en adelante, “MCOCDE”) o en la norma interna si no hay ningún convenio para evitar la doble imposición (“CDI”, en lo sucesivo) suscrito entre ambos países.

Justificar la residencia fiscal supone acreditar un factor de hecho que resulta imprescindible para adecuar toda actuación fiscal antes de cualquier desplazamiento, ya que nos evitaremos problemas como el de la doble residencia, nos eximirá en gran medida incoar procedimientos amistosos por esta razón y nos colocará “bajo el paraguas” del CDI oportuno.

  • Doble tributación: Hablando de fiscalidad en la que intervienen al menos dos jurisdicciones distintas, e
    ste riesgo se plantea como una cuestión de obligado estudio para prevenir este hecho, el cual en algunas ocasiones es ineludible al cien por cien.

Por un lado, lo primero que se debería analizar es si la jurisdicción de destino recibe la denominación de paraíso fiscal o no.[2] Si un trabajador deviniere residente fiscal en un territorio recogido en la “lista negra”, puede que se le aplique la llamada “cuarentena fiscal” (artículo 8.2 LIRPF) y que se penalice a dicho trabajador haciéndole tributar por su renta universal en el IRPF de dos países distintos. Además, tras la introducción en nuestro ordenamiento del artículo 95 bis LIRPF podría también suponer que tenga que tributar por las plusvalías latentes no realizadas en el momento del cambio de residencia.

Por otro lado, resulta imprescindible saber con qué mecanismos e incentivos contamos, tanto en residencia como en fuente, para paliar este efecto fiscal.

  • Manifestación del “exit tax” o “impuesto de salida”: Dependiendo del lugar de residencia dentro del territorio español previo a un desplazamiento con cambio de residencia al extranjero, como veremos a continuación, puede que tengamos que tributar en el IRPF por las plusvalías latentes de acciones y/o participaciones.
  • Inadecuada aplicación de incentivos fiscales: Estrictamente hablando no nos encontramos ante un riesgo, pero lógicamente tiene un efecto directo en el coste fiscal del desplazamiento del trabajador.

1.2.- Riesgos para la empresa.-

  • Incorrecta práctica de retenciones: Posibilidad de no practicar las retenciones ante la correcta Administración Tributaria y por la debida cuota devengada, originándose la correspondiente contingencia.

Además, la falta de previsión y coordinación con el trabajador puede originar la exclusión en la aplicabilidad de alguno de los regímenes más beneficiosos para su tributación personal. Por ello, resulta imprescindible valorar los instrumentos que la normativa nos otorga para neutralizar cuestiones como, por ejemplo, sería la imprevisibilidad de la duración de determinados desplazamientos. Uno de estos instrumentos sería la posibilidad existente de que un no residente anticipe durante un periodo impositivo las retenciones por el IRPF como si de un residente se tratase, o por el contrario, que un residente aplique el régimen de retenciones propio del IRNR cuando prevé que a final de ese mismo periodo impositivo dejara de ser contribuyente por el IRPF.

  • Constitución incidental de un establecimiento permanente en el país de destino: Dependiendo de a qué clase de trabajador se decida desplazar puede que se den las condiciones exigidas por el artículo 5.5 MCOCDE, para que el trabajador desplazado origine la constitución de un establecimiento permanente en la jurisdicción de destino (a través de la figura alternativa del “agente dependiente o representante autorizado”) cuando esa no era nuestra intención.

El supuesto mencionado se originaría, con las excepciones propias del citado artículo, cuando el desplazado sea un trabajador por cuenta ajena, con dependencia respecto de su empleador tanto jurídica como económica, que tenga y ejerza con habitualidad en un estado contratante poderes que le faculten para concluir contratos vinculantes en nombre de la empresa.

  • Operaciones vinculadas/deducibilidad gastos: Estos dos riesgos tienen una manifestación casi correlativa. A modo de ejemplo, la determinación de un establecimiento permanente en el extranjero a través de la figura del agente dependiente (ostentaría la consideración de persona vinculada con la sociedad matriz residente, según el artículo 18.2.i) LIS), podría originar la no deducibilidad de determinados gastos.

SEGUNDO.- RÉGIMEN DE LOS EXPATRIADOS EN LA LIRPF: ÚLTIMAS MODIFICACIONES.-

El régimen fiscal aplicable a trabajadores desplazados, tras la aprobación de la Ley 26/2014, de 27 de noviembre, apenas ha sufrido alteración alguna en relación a los incentivos existentes para trabajadores desplazados residentes fiscales en España.

Continuidad normativa que no la encontraremos en el supuesto en el que el trabajador desplazado cambie de residencia y deja de ser contribuyente en el IRPF a partir de 2015. En este sentido, la novedad introducida por la Ley 26/2014 en la propia LIRPF, consiste en el establecimiento a través del artículo 95 bis de un régimen de “exit tax”, el cual responde a un creciente anhelo de los países de garantizar casi a cualquier precio su soberanía fiscal.

2.1.- Exención por rendimientos del trabajo percibidos por trabajos efectivamente realizados en el extranjero del artículo 7 p) LIRPF.-

Comúnmente conocido como “régimen fiscal de expatriados”, siempre ha sido uno de los incentivos, que por su importante reflejo, tanto en la cuota diferencial del sujeto pasivo como en el efecto financiero (al tratarse de una exención su aplicabilidad no lleva aparejadas retenciones), ha sido un incentivo de gran aplicación entre los contribuyentes residentes en España que son trasladados temporalmente a trabajar al extranjero.

El principal efecto fiscal regulado en el artículo 7.p) LIRPF y 6 RIRPF, consistiría en una exención en base imponible general cuyo límite máximo se establece en 60.100 euros y que se aplicará a las retribuciones devengadas durante los días de estancia en el extranjero.

La exención no ha sufrido modificación alguna a través de la última reforma fiscal “integral” de la LIRPF, por lo que a partir del 2015, para el posible acogimiento a la exención se deberán seguir cumpliendo los mismos requisitos exigidos que con anterioridad:

  • Que dichos trabajos se realicen para una empresa o entidad no residente en España o un establecimiento permanente radicado en el extranjero.
  • Que en el territorio en que se realicen los trabajos se aplique un impuesto de naturaleza idéntica o análoga a la de este impuesto y no se trate de un país o territorio considerado como paraíso fiscal.
  • Incompatibilidad con el régimen de excesos del artículo 9.A.3.b) RIRPF (régimen descrito en el siguiente punto)

Si bien, estos son los principales rasgos del régimen, existe una enorme casuística, tanto doctrinal como jurisprudencial, que habría que tener en cuenta y examinar en cada caso concreto.

2.2.- Otros beneficios.-

Aunque sea de forma meramente enunciativa, conviene plasmar a continuación los demás incentivos fiscales a la expatriación, los cuales tampoco sufrieron modificación alguna tras la aprobación de la Ley 26/2014:

  • “Régimen de excesos” (artículo 9.A.3.b) RIRPF): Exención en IRPF de los excesos que perciban los empleados en relación con aquellas rentas que percibirían del mismo pagador en el supuesto de hallarse en España. Como ya se ha señalado, el régimen es incompatible con la exención por rendimientos del trabajo percibidos por trabajos efectivamente realizados en el extranjero.
  • Exención de las dietas por desplazamientos fuera de España (artículo 9.A.3.a) RIRPF):
    • Límite exento por cuando hay pernoctación: 91,35 euros.
    • Límite exento por no hay pernoctación: 48,08 euros.
    • Los gastos de estancia: siempre exentos hasta el importe que se justifique.
  • Exención de las cantidades abonadas por traslado de domicilio que exija cambio de residencia (artículo 9.B.3 RIRPF): Las cantidades abonadas deben corresponder exclusivamente, a gastos de locomoción y manutención del contribuyente y de sus familiares durante el traslado y a gastos de traslado de su mobiliario y enseres.

Esta última exención se aplicará siempre y cuando dicho cambio de residencia sea inferior a 9 meses de duración (artículo 9.A.3 RIRPF).

1.3.- El nuevo “Exit Tax” del artículo 95 bis LIRPF.-

Este nuevo artículo 95 bis y 121 y siguientes del RIRPF, suponen toda una revolución en el nuestro pais,[3] ya que estamos ante un hecho imponible de los denominados en el argot fiscal como “exit tax” o “impuesto de salida”. Tal y como anticipa el propio Preámbulo de la Ley 26/2014, mediante este nuevo hecho imponible se “establece la tributación de las ganancias tácitas derivadas de acciones o participaciones en entidades relevantes que se pondrá de manifiesto en los supuestos en los que el contribuyente traslade su residencia fiscal a otro país antes de enajenar dicha cartera”.

El artículo señala, que siempre el contribuyente por IRPF hubiera tenido tal condición durante al menos 10 de los 15 períodos impositivos anteriores al último período impositivo que deba declararse por ese impuesto, se gravarán en la base imponible del ahorro (artículo 46.b LIRPF), las diferencias positivas entre el valor de mercado (a 31 de diciembre del último año que deba declararse por el IRPF) y el de adquisición de las acciones o participaciones de cualquier entidad, siempre que:

  • El valor de mercado de las acciones o participaciones exceda, conjuntamente de 4.000.000 de euros.
  • Si no supera dicho importe, que en la fecha de devengo del último periodo impositivo que deba declararse por IRPF, el porcentaje de participación sea superior al 25% si el valor supera 1.000.000 euros (en este caso, solo se incluirán las ganancias respecto de estas.)

Respecto de los plazos de autoliquidación, en caso de estar obligado a su presentación, se verán alterados dependiendo básicamente de los siguientes factores:

  • Factor territorial: La Ley diferencia entre supuestos que variarán dependiendo de si el país de nueva residencia es, un país miembro de la Unión Europea o del Espacio Económico Europeo con el que exista un efectivo intercambio de información tributaria, o es un país calificado como paraíso fiscal.
  • Factor temporal: Dependiendo de si se trata de un cambio de residencia definitivo o temporal.
  • Factor causal: Basándose en si los motivos que justifican el traslado son laborales o de otra índole.
  • Factor transaccional: Si se produce o no una transmisión inter vivos de las acciones o participaciones.

Por último, es reseñable el hecho de que esta norma todavía no ha sido recogida en la normativa foral de los denominados constitucionalmente como territorios forales: Álava, Bizkaia, Gipuzkoa y Navarra. Al menos por ahora, los residentes en estos territorios que planteen cambiarse de residencia al extranjero, gracias a la capacidad normativa en relación al IRPF[4] que otorga, tanto Concierto Económico al País Vasco como el Convenio a Navarra, quedan salvaguardados de la aplicabilidad de un régimen semejante al descrito en el artículo 95 bis LIRPF.

TERCERO.- RÉGIMEN ESPECIAL DE TRABAJADORES DESPLAZADOS A TERRITORIO ESPAÑOL O IMPATRIADOS: ÚLTIMAS MODIFICACIONES.-

El régimen fiscal especial para trabajadores desplazados vigente, tiene su origen la Ley 62/2003 de 30 de diciembre y desarrollada por el Real Decreto 687/2005, régimen que se justificaba desde un inicio en la atracción de talento laboral a nuestro país, aunque en la práctica y sobre todo al principio, se aprovechó por futbolistas profesionales llegándose a denominar a la propia Ley como la “Ley Beckham”.

El beneficio fiscal para los contribuyentes que se acojan a este régimen especial radica en la posibilidad de elección por el trabajador desplazado por tributar exclusivamente por las rentas obtenidas en territorio español según un criterio de territorialidad por IRNR (salvo los rendimientos del trabajo, los cuales en todo caso tributarán en España), en vez de siguiendo criterio personal y tributar por la renta mundial en el IRPF.

A través de este incentivo recogido en el artículo 93 LIRPF y en los artículos 113 a 120 del RIRPF conseguiríamos, en primer lugar tributar a tipos impositivos inferiores por IRNR que en IRPF (tipo marginal aplicable a los rendimientos del trabajo: en torno al 50% dependiendo de la Comunidad Autónoma de residencia),[5] asimismo la tributación por IRNR también podrá evitar de manera más efectiva una doble tributación que por IRPF y el articulo 80 LIRPF, sobre todo cuando el impuesto satisfecho en el extranjero sea inferior al tipo medio de gravamen español.

Como era lógico pensar, el régimen especial no es de aplicación perpetua sino que en caso de optar por él y tributar por IRNR, éste será aplicable durante el período impositivo en que se efectúe el cambio de residencia y durante los cinco períodos impositivos siguientes, siempre y cuando se cumplan los siguientes requisitos:

  • No haber residido en España durante los 10 períodos impositivos anteriores a aquel en el que se produzca el desplazamiento.
  • Que la consecuencia del desplazamiento sea cualquiera de las siguientes circunstancias:
    • Contrato de trabajo: A partir del 1 de enero de 2015, se exceptúan expresamente a los deportistas profesionales. [6]
    • Adquisición de la condición de administrador: Siempre que sea en una entidad, en la que si es que también participa en su accionariado, en ningún caso lo haga por encima del 25% exigido (antes 5%) para que determine la vinculación según el artículo 18 de la LIS.

Con anterioridad a la última reforma fiscal, se establecía una serie de requisitos que han sido suprimidos con la redacción actual:

  • Que las retribuciones previsibles derivadas del contrato de trabajo en cada uno de los períodos impositivos en los que se aplique este régimen especial no superasen la cuantía de 600.000 euros anuales.
  • Que al menos el 85% de los trabajos se realizasen efectivamente en territorio español (70% cuando se realizasen para empresas en el seno de un grupo multinacional), tributando proporcionalmente en cada país. Ahora, la totalidad de los rendimientos del trabajo se entenderán obtenidos en territorio español.
  • Que dichos trabajos se realicen para una empresa o entidad residente en España o para un establecimiento permanente situado en España de una entidad no residente en territorio español.

3.1.- Cálculo de la liquidación.-

En la base liquidable se distinguirá entre dos tipos de rentas, las cuales tributarán en España siempre y cuando así lo determinen las internas españolas en relación con el CDI oportuno:

  • Ganancias patrimoniales, dividendos e intereses (artículo 25.1. f) del LIRNR), a las cuales se les aplicará la siguiente escala:

tabla

  • Generalidad de rentas (no contenidas en el artículo 25.1.f) LIRNR): Se gravarán al 24%.

Ahora bien,cuando las retribuciones durante el año excedan de 600.000 euros, el porcentaje de gravamen sobre el exceso será del 47% en el año 2015 (45% en 2016).

En general, las retenciones se calcularán en base a lo dispuesto en la normativa de IRNR. Respecto de las retenciones sobre los rendimientos del trabajo, serán siempre del 24% salvo que las retribuciones satisfechas por un mismo pagador de rendimientos del trabajo previsibles durante el año natural excedan de 600.000 euros, el porcentaje de retención aplicable al exceso será el 47% (45% a partir de 2016).

3.2.- Régimen transitorio.-

La nueva regulación mantiene la posibilidad para aquellos que se hubieran acogido al régimen especial con anterioridad al 1 de enero de 2015, de seguir tributando según la redacción anterior, para ello deberán solicitarlo en la autoliquidación relativa al periodo impositivo 2015. Nótese, que se seguirá tributando a un tipo del 24,75% y que se producirá cierto déficit en las retenciones, ya que el tipo fijo de estas seguirá siendo del 24%.

3.3.- Aspectos formales para la aplicación del régimen especial: forma y plazos.-

El contribuyente para poder acogerse a este régimen opcional deberá presentar la correspondiente comunicación a través del modelo 149 ante la Administración Tributaria, este mismo modelo será el oportuno para renunciar a este régimen (renuncia que se deberá hacer durante los meses de noviembre y diciembre) o cuando quede excluidos del mismo por incumplir alguna de las condiciones.

El plazo para optar es de 6 meses desde la fecha de inicio de la actividad que conste en el alta en la Seguridad Social en España o en la documentación que le permita, en su caso, el mantenimiento de la legislación de Seguridad Social de origen. El hecho de ejercitar la opción por el régimen especial fuera de plazo puede suponer la no inclusión en el mismo.[8]

CONCLUSIONES FINALES

En definitiva, dada la casuística existente en la operativa empresarial, la diversidad de legislaciones en juego y la “diarrea legislativa” en materia tributaria sobre estos aspectos, resulta imprescindible una planificación minuciosa e individualizada de los desplazamientos internacionales de personas a la hora de afrontar la internacionalización del proyecto empresarial, cuestión que resulta del todo más beneficioso tanto para la empresa como para el trabajador.

Este hecho, que en un primer lugar parece ralentizar la internacionalización del capital humano de la empresa, al mismo tiempo nos ahorrará cualquier tipo de conflicto previsible entre ambas partes, provocado en la mayoría de los casos por la discordancia a la hora de aplicar unas normas que tienen un claro efecto bidireccional, imponiendo cargas a las dos partes de la relación laboral.

[1] La planificación, que aunque no sea objeto de estudio en este artículo no deberá limitarse a la aplicación del derecho fiscal sustantivo, sino que deberá también extenderse al estudio de las obligaciones formales en cada país. Adquieren gran importancia en el ámbito del intercambio de información en materia tributaria.

[2] V. Disposición adicional primera de la Ley 36/2006, de 29 de noviembre, en relación con lo dispuesto en el Real Decreto 1080/1991, de 5 de julio y el Informe de la Dirección General de Tributos, de 23 de diciembre de 2014, sobre la vigencia de la lista actual de paraísos fiscales respecto a la entrada en vigor de la disposición final segunda de la Ley 26/2014

[3] Lo más parecido hasta el momento dentro de nuestro ordenamiento, aunque no es en puridad un exit tax, es la regla de imputación por cambio de residencia contemplada en el artículo 14.3 LIRPF.

[4] V. artículo 6 de la Ley 12/2002, de 23 de mayo, y artículo 9 de la Ley 28/1990, de 26 de diciembre.

[5] V. artículo 46.1.b) de la Ley 22/2009, de 18 de diciembre.

[6] Relación laboral especial regulada por el Real Decreto 1006/1985, de 26 de junio.

[7] Cambio realizado en la Disposición adicional trigésima primera de la LIRPF tras la aprobación del Real Decreto-ley 9/2015, de 10 de julio, previa introducción por la Ley 26/2014, de 27 de noviembre de los tipos aplicables en 2016 y siguientes y en la primera mitad del periodo impositivo 2015

[8] V. Sentencia de la Audiencia Nacional, Sala de lo Contencioso-Administrativo, Sección 4ª, de 19 de septiembre de 2012 y Resolución del TEAC, de 30 de junio de 2011, entre otras.

 

Elisa Lemus y Tomás Barrilero

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