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An Argentine citizen already benefiting from the special regime under Article 93 LIRPF via employment (periods 2023-2028) wishes to end the employment relationship and start a software development economic activity. The DGT concludes that, unlike transitioning to another employment relationship, establishing a permanent economic activity in Spain results in exclusion from the regime, except where the activity is classified as entrepreneurial (case 3) or as a highly qualified professional in an emerging company or R&D+i activities (case 4).
Contributors under the Beckham regime lose their special status upon starting a permanent economic activity in Spain, unless the activity qualifies as entrepreneurial or highly qualified in R&D+i or emerging enterprises.
The tax team reviews your specific situation.
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