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.