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A Belgian resident asks whether they can apply the special tax regime for relocation to Spain as administrator of a new Spanish company they will manage. The DGT states that a causal link must exist between relocation and the position, and that no income should be derived through a permanent establishment.
Question posed: Whether the special taxation regime regulated in Article 93 of the Personal Income Tax Law will apply to him. In particular, it is desired to know whether the fact that the administrator of the Spanish company (the applicant) himself materially executes the activity could have an effect.
To apply the special regime under Article 93.1 of the Personal Income Tax Law (LIRPF), the relocation to Spain must be a consequence of acquiring the status of administrator. If the company is a holding company, the administrator may not hold a shareholding that makes it a related entity. Likewise, income must not be obtained that would be classified as being derived through a permanent establishment in Spanish territory. The existence of a causal relationship is a matter of fact that must be proven.
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