Skip to content
V1582-24 ·1 July 2024 ·consulta-vinculante Medium impact
Tax

No causal link between move to Spain and becoming administrator

A couple resident in Germany asks whether they can benefit from the special tax regime under Article 93 of the LIRPF after setting up a Spanish company and being appointed administrators. The DGT replies that this is not possible due to the absence of a causal link between their move to Spain and becoming administrators.

In 6 key points

How it affects those involved

The absence of a causal connection between relocation to Spain and assuming administrative roles prevents eligibility for the special tax regime under Article 93 of the LIRPF.

Lifecycle

2024-07-01PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

Does this provision affect you?

The tax team reviews your specific situation.

Talk to the tax team
This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
Email
Contact