Quote:
Spain
Income that residents of Spain receive as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U.S. income tax if the residents do not have a fixed base available to them in the United States for performing the services. If they have a fixed base, they are taxed only on the income attributable to the fixed base.
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https://www.irs.gov/publications/p90...link1000219372
It's more of a 'get out of jail card' for a US payor of non-resident independent contractor's commissions. An exemption form from 1099 Miscellaneous Income annual reporting requirement.