2026

May

  • 27.05
    Inversión inmobiliaria Frequently asked questions about non-resident property taxation in Spain
  • 27.05
    Wealth & Succession Frequently asked questions about Spanish Inheritance and Gift Tax for the foreigner becoming a Spanish tax resident
  • 27.05
    Tax residence Frequently asked questions about Spanish tax residence (art. 9 LIRPF)
  • 27.05
    Cambio de residencia Frequently asked questions about the Spanish exit tax (art. 95 bis LIRPF)
  • 27.05
    Empresa familiar Interposing a holding company as administrator can cause the rest of the family group to lose the family-business exemption
  • 27.05
    Empresa familiar TEAC embraces the Supreme Court doctrine: the full-time employee requirement in property rental can be met at group level
  • 27.05
    Planificación fiscal TEAC extends the FIFO method to gifts of homogeneous securities: an identification rule, not a valuation rule
  • 27.05
    International taxation Transfer pricing adjustments and VAT: the CJEU judgment in Stellantis Portugal requires a legal relationship with reciprocal and identifiable performances
  • 12.05
    Beckham regime Frequently asked questions about the Beckham Law
  • 12.05
    Beckham regime Twelve must-review subjects before relocating to Spain under the Beckham regime
  • 05.05
    Tax procedure Home entry under article 113 of the LGT: the judicial order must individually motivate digital access
  • 05.05
    Tax procedure The right to deny the tax Administration entry into the home: the specific reasoning of the judicial order also reaches digital access
  • 02.05
    Foreign private foundation Law 49/2002 regime and non-resident foundations: prior election and formal notification, no shortcuts
  • 02.05
    Foreign private foundation The tax regime of Law 49/2002 does not apply automatically to non-resident foundations: the TEAC requires the prior election to exclude taxation under the IRNR

April

  • 28.04
    Crypto-assets The CJEU clarifies the VAT treatment of the exchange between a video-game virtual currency and traditional currencies
  • 28.04
    Crypto-assets Video-game virtual currency and VAT: the CJEU confines the Hedqvist doctrine and returns the transaction to the general regime
  • 25.04
    International taxation The Spanish Supreme Court confirms in the VELCRO case the cross-cutting reach of the beneficial-owner concept in international taxation
  • 25.04
    International taxation VELCRO: the beneficial owner operates cross-cuttingly over Directive and treaty
  • 22.04
    Beckham regime Beckham regime: the prior five-year period is measured in tax residence, not in physical presence
  • 22.04
    Beckham regime The special inbound-expatriates regime requires prior residence outside Spain for five complete tax periods
  • 16.04
    Wealth & Succession Family business: negative income from other economic activities does not enter the denominator of the 50%
  • 16.04
    Wealth & Succession Negative income from other economic activities is not computed in the 50% management-functions calculation under the family-business exemption
  • 09.04
    Tax residence Criminal Chamber of the Spanish Supreme Court and the tax-residence certificate: a presumption that yields to compelling evidence
  • 09.04
    Tax residence The Criminal Chamber of the Spanish Supreme Court rules on the presumption of validity of tax-residence certificates in criminal proceedings

March

  • 30.03
    VAT Penalties of article 171.One.4 of the VAT Act for reverse charge: the proportionality doctrine is alive
  • 30.03
    VAT Penalties under article 170.Two.4 of the VAT Act for reverse charge may be annulled as disproportionate
  • 25.03
    Tax procedure Notification at the tax domicile despite the designation of a representative: the TEAC consolidates the rule of purpose achieved
  • 25.03
    Tax procedure Tax notification at the tax domicile despite the designation of a representative: the TEAC qualifies the Spanish Supreme Court's doctrine under the rule of purpose achieved
  • 11.03
    Tax procedure A self-assessment may not be the subject of the special review procedure for acts that are null and void
  • 11.03
    VAT Mixed holding and intragroup transfer of participations: differentiated sector under VAT, save autonomous economic unit
  • 11.03
    Tax procedure Tax self-assessment: rectification under article 120.3 of the LGT as the ordinary review channel
  • 11.03
    VAT The intragroup transfer of participations by a mixed holding company forms a differentiated sector for VAT purposes, save where it entails the transfer of an autonomous economic unit
  • 02.03
    Beckham regime International remote work from Spain opens the Beckham regime to the foreign executive, but leaves unresolved the risk of permanent establishment of the employer
  • 02.03
    Beckham regime International remote work from Spain: the Beckham regime opens, but the risk zone is the employer

January

  • 27.01
    Wealth & Succession Family-business exemption: the remuneration received from companies transferred in the framework of a restructuring is excluded from the 50% calculation at the level of the holding company
  • 27.01
    Wealth & Succession Restructuring into a holding: the prior remuneration of the subsidiaries does not cloud the 50% of the family business
  • 27.01
    Wealth & Succession The total division to facilitate generational handover is a valid economic reason for the purposes of the FEAC regime of the Corporate Income Tax
  • 27.01
    Wealth & Succession Total division to prepare generational handover: valid economic reason under the FEAC regime

2025

December

  • 18.12
    Beckham regime Compensation for a non-compete covenant received under the Beckham regime is not taxed in Spain if it derives from activity carried out abroad

September

  • 18.09
    Wealth & Succession The DGT consolidates the tax transparency of the foreign trust: the inter vivos contribution is not a gift for IRPF purposes and the mortis causa transfer to the resident beneficiary opens access to the regional ISD legislation

July

  • 15.07
    Tax residence The Spanish Supreme Court reiterates the doctrine on the foreign tax residence certificate, but the first tie-breaker rule of the treaty fixes residence where the contributor identifies a permanent home
  • 03.07
    Beckham regime The DGT consolidates the operative map of the Beckham regime in the administrator modality: causation, passive-wealth filter and continuity

June

  • 10.06
    Trusts International trusts and inbound workers: the regime of article 93 of the Personal Income Tax Act does not neutralise the resident beneficiary's inheritance tax exposure under personal obligation

2024

September

  • 26.09
    Beckham regime The DGT confirms that the office of trustee and general director of a Spanish foundation qualifies as administrator for the purposes of the Beckham regime, and clarifies compatibility with foreign board appointments
  • 17.09
    Beckham regime The 100 % quasi-shareholder may benefit from the Beckham regime since Law 28/2022, unless the entity is a passive-wealth entity

July

  • 22.07
    Tax residence The UK tax residence certificate under the remittance basis regime does not establish residence for the purposes of the Spain-UK tax treaty

2023

June

  • 12.06
    Tax residence The Spanish Supreme Court closes the door on AEAT: a tax residence certificate issued by another State under a tax treaty cannot be displaced by domestic circumstantial evidence

2021

March

  • 11.03
    Wealth & Succession The foreign transfer of holdings in a German KG holding Spanish real estate to a Familienstiftung is not subject to ITPAJD, but the DGT leaves the 314 LMV rule and the indirect real-estate capital gain under IRNR unaddressed

2016

February

  • 25.02
    Foreign private foundation The Liechtenstein Stiftung has autonomous legal personality under Spanish law: the contribution of Spanish real estate triggers inheritance and gift tax by in rem obligation