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V1970-25 ·17 October 2025 ·consulta-vinculante Medium impact
Tax

Requirements to access the special regime under Article 93 of the LIRPF as an administrator

A hotel group shareholder moving to Spain to become the sole administrator of a new company asks whether they can apply for the special regime under Article 93 of the LIRPF. The DGT states that a causal link must exist between the move and the appointment, and that the company must not be a patrimonial entity if the administrator holds a stake linking them to it.

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2025-10-17PublishedPublished 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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