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A British citizen resident in the Isle of Man stayed over 183 days in Spain due to a serious health issue preventing travel. The DGT states that, as there is no double taxation treaty with the Isle of Man, domestic rules apply and the taxpayer is considered a tax resident in Spain.
Cuestión planteada Si, debido a las circunstancias excepcionales que concurren, el consultante puede ser considerado como no residente fiscal en España; aún conociendo que el artículo 9 de la Ley del IRPF no establece excepción alguna al respecto, y ante la inexistencia de convenio para evitar la doble imposición entre Isla de Man y España.
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