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V2454-25 ·11 December 2025 ·consulta-vinculante Medium impact
Tax

Special tax regime requires causal link between appointment and relocation

A Swedish national seeks to know if he can apply the special tax regime under article 93 of the LIRPF upon moving to Spain to act as administrator of an real estate investment company. The DGT states that access to the regime requires a causal link between the move and the position, and that the company must not be considered a patrimonial entity if its participation creates a link.

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2025-12-11PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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