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A Salvadoran national resident in the UK, owner of 90% of a Finnish artificial intelligence company, asks whether he can access the special regime under article 93 LIRPF by moving to Spain to become administrator of the Spanish subsidiary to be established. The DGT examines the three requirements: no prior residence in the five preceding periods, a causal link between the move and the administrator role, and that the subsidiary is not a patrimonial entity.
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