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An Argentine citizen already benefiting from the special regime under Article 93 LIRPF via employment (periods 2023-2028) wishes to end the employment relationship and start a software development economic activity. The DGT concludes that, unlike transitioning to another employment relationship, establishing a permanent economic activity in Spain results in exclusion from the regime, except where the activity is classified as entrepreneurial (case 3) or as a highly qualified professional in an emerging company or R&D+i activities (case 4).
Question posed: Whether, in the event that the described modification is carried out, the special regime may continue to be applied.
Art. 93.1.c LIRPF prohibits obtaining income through a permanent establishment in Spain during the term of the regime, except for the cases set out in items 3 and 4 of art. 93.1.b. The commencement of a software economic activity without obtaining a favorable report from ENISA as an entrepreneurial activity, nor proving the status of a highly qualified professional pursuant to art. 71 of Law 14/2013, determines non-compliance with the requirement and exclusion from the regime with effects in the same tax period, which must be communicated within one month (art. 118 RIRPF).
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