How the DGT's position has evolved
Current position
The special regime under Article 93 of the LIRPF (Personal Income Tax Law) is maintained as long as the legal requirements are met and income is not obtained through a permanent establishment in Spain. The termination of the employment relationship that motivated the relocation does not lead to exclusion if a new employment or administrator activity is started that meets the requirements. The existence of brief periods of inactivity or the addition of a second part-time employment relationship are not grounds for exclusion.
The DGT's position remains constant in the interpretation of the causes for exclusion from the special regime. Recent rulings confirm that the cessation of the original activity or the coexistence of multiple employment relationships does not break the beneficiary status, provided that the purpose of the regime is preserved.
Turning points
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Establishes that voluntary termination to start a new employment relationship or brief periods of unemployment do not constitute grounds for exclusion.
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Specifies that the simultaneous obtaining of income from a second part-time employment relationship does not cause exclusion from the regime.
Analysis based on 24 of 25 rulings with a stated position. Updated 24 September 2026.