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A private equity manager with carried interest channelled through Guernsey entities seeks to know whether, after restructuring payments via a Luxembourg fund, its Spanish resident employees could benefit from the 50% DA 53ª LIRPF integration regime. The DGT concludes that the special economic rights still derive from Guernsey entities (non-cooperative jurisdiction) and that the restructuring is merely a change in payment chain without altering the underlying rights.
The tax team reviews your specific situation.
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