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MEDIUM
FISCAL

Special tax regime requires causal link between appointment and relocation

V2454-25

Prepared and reviewed by the BMC editorial team  ·  Methodology

Technical details

Type
consulta-vinculante (what is this?)
Identifier
V2454-25
Published
11 Dec 2025

Summary

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.

In 6 key points

Lifecycle

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

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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