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MEDIUM
FISCAL

Special tax regime for LIRPF administrators requires proof of causal link to Spain move

V1068-25

Prepared and reviewed by the BMC editorial team  ·  Methodology

Technical details

Type
consulta-vinculante (what is this?)
Identifier
V1068-25
Published
25 Jun 2025

Summary

A taxpayer asks whether they can apply the special tax regime under article 93 of the LIRPF after moving to Spain following appointment as administrator of a company. The DGT states that a causal link must exist between the move and the position, and that if the company is a patrimonial entity, the allowed shareholding is limited.

In 6 key points

Lifecycle

2025-06-25PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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