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V0948-25 ·29 May 2025 ·consulta-vinculante Low impact
Tax

US citizens resident in Spain cannot deduct 'transition tax' from their IRPF

A US citizen resident in Spain asks whether the US 'transition tax' on undistributed reserves is deductible in their IRPF or constitutes a capital loss. The DGT responds that it is neither deductible nor a capital loss.

In 6 key points

How it affects those involved

US residents in Spain cannot claim the 'transition tax' as a deduction in their IRPF and it does not count as a capital loss.

Lifecycle

2025-05-29PublishedPublished 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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