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V2654-24 ·27 December 2024 ·consulta-vinculante Medium impact
Tax

Causal link required between move and administrator role

A non-resident sole administrator of a Spanish company asks if the startup special regime applies. The DGT states that a causal link must be proven between the move to Spain and appointment as administrator, and that no permanent establishment income is generated.

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2024-12-27PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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