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V0186-26 ·30 January 2026 ·consulta-vinculante Low impact
Tax

Tax residence is determined by physical presence or the center of economic interests

A Spanish postdoctoral researcher on contract at a Spanish university undertaking a stay in Sweden seeks advice on tax residency and the application of the exemption under Article 7.p) of the Spanish Personal Income Tax Law. The DGT states that the exemption requires the work to be carried out for a non-resident entity and that the effective beneficiary of the services must be that foreign entity.

In 6 key points

How it affects those involved

Clarifies conditions for the exemption of foreign work under Spanish tax law, particularly regarding the effective beneficiary and the nature of the recipient entity.

Lifecycle

2026-01-30PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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