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MEDIUM
FISCAL

Causal link required between move to Spain and appointment as administrator

V1614-25

Prepared and reviewed by the BMC editorial team  ·  Methodology

Technical details

Type
consulta-vinculante (what is this?)
Identifier
V1614-25
Published
15 Sept 2025

Summary

A Swedish national asks whether he can claim the special tax regime for displaced persons (Art. 93 LIRPF) upon becoming administrator and executive director of a Spanish company. The DGT states that a causal link must be proven between the move to Spain and the position, as well as participation limits if the company is a patrimonial entity.

In 6 key points

Lifecycle

2025-09-15PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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