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V1209-25 ·3 July 2025 ·consulta-vinculante Medium impact
Tax

Special regime requires causal link between relocation and appointment

The DGT clarifies that a causal relationship must exist between relocation and the appointment as administrator, and that income cannot be derived through a permanent establishment.

In 6 key points

Lifecycle

2025-07-03PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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