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A company asks whether a worker already in Spain for studies can access the special regime under Article 93 of the LIRPF after obtaining a residence permit for highly qualified individuals. The DGT responds that no such link exists between the move and the start of the employment relationship.
Question posed: Whether they may opt for the special tax regime provided for in Article 93 of the Personal Income Tax Law, taking into account that there is no relocation to Spain by the worker because they were already in a situation of stay for studies.
To apply the special regime under Article 93.1 of the Personal Income Tax Law (LIRPF), the relocation to Spain must occur as a consequence of an employment contract or the acquisition of the status of administrator. In this case, as the worker had previously been in a situation of stay for studies, the requirement of causality between the relocation and the new employment relationship is not met. Therefore, they cannot opt for said regime.
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