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A Swedish national, tax resident in Sweden in 2023, takes up a global commercial director position at a Madrid-based consultancy and asks whether he can apply for the special regime under art. 93 LIRPF. The DGT confirms that he may opt for the regime if he acquires Spanish tax residency in 2024 as a result of starting the employment relationship, has not been a Spanish tax resident in the five preceding tax periods, and does not derive income through a permanent establishment in Spain.
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