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A Dutch national asks whether the special regime under Article 93 of the Spanish Personal Income Tax Law applies when joining a Spanish company as General Manager. The DGT states that it is possible if there is a causal link between the start of the employment relationship and the relocation, and all other legal requirements are met.
Question posed: Whether the special tax regime provided for in Article 93 of the Personal Income Tax Law is applicable to them.
To apply the special regime under Article 93 of the Personal Income Tax Law (LIRPF), the taxpayer must have acquired tax residence in Spain as a consequence of their relocation. It is required that they have not been a resident in the previous ten tax periods, that the relocation is due to an employment contract (or management of an entity), and that they do not derive income from a permanent establishment. In this case, if the employment relationship and the causality between the contract and the relocation exist, the requirement of letter b) would be met.
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