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Un profesional residente en el Reino Unido consulta si puede aplicar el régimen especial de tributación (art. 93 LIRPF) al trasladarse a España para liderar una filial. La DGT indica que podrá optar por este régimen si cumple los requisitos de no haber sido residente en España anteriormente, si el desplazamiento es consecuencia de un contrato laboral con un empleador español y si no obtiene rentas de un establecimiento permanente.
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