Skip to content
Back to index
V2590-25 22 December 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · régimen especial

UK national asks if special regime applies to move to Spain as tech subsidiary manager

A UK national queries whether the special regime under Article 93 of the IRPF applies to relocating to Spain to manage a technology subsidiary. The DGT states that a causal link must be proven between the move and appointment, along with fulfilling other residence and income requirements.

The question raised

Whether the special tax regime provided for in Article 93 of the Personal Income Tax Law will be applicable to you.

The DGT's ruling

To apply the special regime, the relocation to Spain must be a consequence of acquiring the status of administrator. A causal relationship must exist and be substantiated with valid means of proof. If the entity is a holding company, the administrator may not hold a shareholding that renders them a related party. Furthermore, the requirements of not having been a resident in Spain in the previous five years and not obtaining income through a permanent establishment must be met.

Book your free first meeting