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A Swedish national, tax resident in Sweden in 2023, takes up a global commercial director position at a Madrid-based consultancy and asks whether he can apply for the special regime under art. 93 LIRPF. The DGT confirms that he may opt for the regime if he acquires Spanish tax residency in 2024 as a result of starting the employment relationship, has not been a Spanish tax resident in the five preceding tax periods, and does not derive income through a permanent establishment in Spain.
Question posed: Whether the special taxation regime regulated in Article 93 of the Personal Income Tax Law will be applicable to him.
Art. 93.1 LIRPF requires: non-residence in Spain during the five tax periods prior to the relocation; that the relocation is a causal consequence of the commencement of an employment relationship with an employer in Spain; and that no income is obtained through a permanent establishment located in Spanish territory. The DGT does not verify the actual existence of the employment relationship, the accreditation of which is the responsibility of other bodies, but confirms that if the described facts were to occur, the regime would be applicable.
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