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MEDIUM
FISCAL

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

V2590-25

Prepared and reviewed by the BMC editorial team  ·  Methodology

Technical details

Type
consulta-vinculante (what is this?)
Identifier
V2590-25
Published
22 Dec 2025

Summary

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.

In 6 key points

Lifecycle

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

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