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V0769-20 ·7 April 2020 ·consulta-vinculante Medium impact
Tax

Requirements for applying the special LIRPF regime for relocation as an administrator

A Belgian national asks whether they can apply for the special LIRPF regime upon moving to Spain to manage a Spanish company with minority ownership. The DGT states that this is possible provided the conditions of no prior tax residency, causal link to the move, and absence of a permanent establishment are met.

In 6 key points

How it affects those involved

The ruling clarifies eligibility criteria for the special LIRPF regime for administrators relocating to Spain, ensuring alignment with tax residency and establishment rules.

Lifecycle

2020-04-07PublishedPublished 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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