How the DGT's position has evolved
Current position
The special regime under Article 93 of the LIRPF (Personal Income Tax Law) requires that the relocation be a consequence of an employment contract or the acquisition of the status of administrator. The taxpayer must not have been a resident in Spain during the ten previous tax periods and must not obtain income through a permanent establishment. Access is possible through teleworking, provided that computer and telematics means are used.
The DGT's position remains constant regarding the requirements of causality and previous residence. The interpretation has been expanded to include teleworking as a valid modality for relocation. The doctrine confirms that failure to comply with the conditions leads to exclusion in the tax period in which it occurs.
Turning points
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Explicitly includes the acquisition of the status of administrator as a valid cause for relocation.
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Establishes that teleworking through computer and telematics means allows access to the regime, regardless of the lack of a visa under Law 14/2013.
Analysis based on 20 of 23 rulings with a stated position. Updated 24 September 2026.