Focused area

Beckham Law tax audits in Spain

A valid election must still be supported when the Spanish Tax Agency tests the underlying facts.

Admission to the Beckham Law does not prevent later review of eligibility, Form 149 and the tax position declared through Form 151.

Reviews often focus on prior residence, the reason for moving, the professional relationship, actual functions, remuneration and international payments. The defence must connect those elements through a coherent chronology and evidence.

Lullius acts for taxpayers and employers from the first request. We review the file, organise the records and build a strategy capable of supporting any later assessment, penalty or appeal.

Focused support

Defending Beckham Law reviews

Initial file review

We examine Form 149, the accreditation document, supporting records, Form 151 returns and subsequent communications to determine the true scope of the review, immediate deadlines and any evidential gaps.

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From the first request

Defence strategy

  • Accreditation does not close the enquiry. The authorities may review initial access, continued eligibility and annual taxation. We define the issue, period and evidence required with precision.
  • Facts carry more weight than labels. What matters is the activity performed, where decisions were made and the real reason for moving. The chronology should rest on contemporaneous records.
  • The first response should anticipate the appeal. Before replying, we assess the legal position, evidential gaps and penalty risk. Each submission preserves arguments that may be needed later.
  • Cross-border evidence, under control. We identify where each record is held, preserve its context and review sensitive material before production. Deadlines and responsibilities remain clearly defined.

Key contacts

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Portrait of Xavier Rubert

Xavier Rubert

Partner

Tax, Tax Litigation, Private Wealth
Portrait of Marta Aparicio

Marta Aparicio

Senior Associate

Tax, Private Wealth
Portrait of Carmen Salom

Carmen Salom

Senior Associate

Tax, Tax Litigation
Portrait of Fernando Flores

Fernando Flores

Senior Associate

Tax, Tax Litigation, Private Wealth, Global Mobility

Let’s consider the whole picture.

Speak directly with a member of our team about your Spanish tax, private wealth or tax litigation matter.

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