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The DGT confirms that applying IRPF rules to resolve succession and donations tax residence disputes includes the CDI criteria, meaning these conventions are used to determine residence.
Question posed: Whether the reference made by the Inheritance and Gift Tax regulations (hereinafter ISD) to the concept of residence provided for in the IRPF regulations also implies the application of the criteria provided in the Spain-Czech Republic DTA to resolve the conflict of residence within the scope of the ISD.
The determination of habitual residence for the ISD is governed by the IRPF rules pursuant to Article 6.2 of the LISD. This reference encompasses the entirety of the IRPF regulations, not being limited solely to the substantive law or its regulation. Consequently, if a DTA determines that a person is not a resident in Spain for IRPF purposes, they shall also not be considered a resident for the ISD by personal obligation.
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