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A Swiss consultant plans to move to Spain in October 2025 to work from his home. The DGT examines whether he will be a fiscal resident in 2025 and how his income from the previous quarter will be taxed.
Cuestión planteada
Si el consultante no es residente fiscal en España en 2025, sus rentas del último trimestre podrían tributar por el IRNR si dispone de una base fija. El domicilio en España se considera lugar de negocios y, al tener vocación de permanencia, constituye un establecimiento permanente. En ese caso, España puede gravar las rentas atribuibles a dicha base fija conforme al Convenio España-Suiza y al TRLIRNR.
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