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Un ciudadano alemán residente en Panamá consulta si puede aplicar el régimen especial de tributación por el IRPF al trasladar su residencia a España para ser administrador de una sociedad. La DGT señala que debe existir causalidad entre el desplazamiento y el nombramiento, y que la sociedad no debe ser patrimonial si el administrador tiene una participación que la vincule.
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