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V1208-25 3 July 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · régimen especial de tributación

Beckham regime maintained if short-term inactivity followed by new administrative role

A displaced worker opting for the Beckham special regime asks whether they lose the benefit upon contract end and starting as administrator of another company with a brief overlap of roles. The DGT confirms that exclusion does not occur if article 93 of the IRPF Law is met.

The question raised

Given the termination as an employee of A and his appointment as an administrator in B, to determine whether the special tax regime continues to apply even if an overlap of positions occurred (he was appointed administrator on December 23, 2024, and his termination as an employee occurred on December 31, 2024) and the registration of the appointment as an administrator in the Mercantile Registry occurred on January 17, 2025 (that is, 17 days after the termination as an employee).

The DGT's ruling

The termination of the employment relationship that prompted the relocation does not imply exclusion from the special regime if the taxpayer begins a new employment or administrator relationship that meets the requirements of Article 93 of the LIRPF. The purpose of the regime to attract individuals to Spain is compatible with brief periods of inactivity or unemployment following the conclusion of the activity that prompted the relocation, provided that a new valid activity is initiated.

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