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V0990-21 20 April 2021 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · régimen especial de tributación

Special regime of Article 93 of the IRPF requires relocation to be linked to becoming an administrator

A Dutch national asks whether he can benefit from the special IRPF regime after being appointed chairman of a Spanish company. The DGT states that a causal relationship must exist between moving to Spain and acquiring the status of administrator.

The question raised

Whether the special tax regime provided for in Article 93 of the Personal Income Tax Law is applicable to him and, primarily, as a consequence of the commencement of his duties as a director of the Spanish company.

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