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V2590-25 ·22 December 2025 ·consulta-vinculante Medium impact
Tax

UK national asks if special regime applies to move to Spain as tech subsidiary manager

A UK national queries whether the special regime under Article 93 of the IRPF applies to relocating to Spain to manage a technology subsidiary. The DGT states that a causal link must be proven between the move and appointment, along with fulfilling other residence and income requirements.

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2025-12-22PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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