Lullius Partners achieves the dismissal of all findings in a complex tax audit regarding the application of Spain’s Beckham Law for a high-net-worth individual and his holding company.
The Challenge
In early 2025, an international executive relocating to Spain, together with his Spanish holding company, faced an intensive tax audit initiated by the Spanish Tax Authorities (AEAT). The main focus of the investigation was the eligibility and correct application of the Special Expat Regime (commonly known as “Beckham Law”)—both in terms of personal income tax treatment and the related compliance obligations for the company acting as employer.
The AEAT questioned several aspects, including:
- The executive’s effective relocation and tax residency status in Spain.
- The substance and formality of the employment contract.
- The deductibility of certain benefits in kind.
- The company’s obligation to apply the correct withholdings and to comply with employer reporting obligations.
Given the potential reputational and financial exposure for both the individual and the company, a robust, highly coordinated defence strategy was required.
The Outcome
Lullius Partners swiftly assembled a multidisciplinary team combining expertise in tax audits, international mobility, and employer compliance.
Following several months of technical exchanges and documentary submissions, the AEAT issued a resolution fully accepting our arguments. The audit was closed with no adjustments, penalties, or further liabilities for either the individual or the company.
Key achievements included:
- Confirmation of the client’s right to the Beckham Regime for the relevant tax years.
- Validation of all company payroll practices and reporting.
- Preservation of the client’s tax savings and peace of mind for future compliance.
- Avoidance of protracted litigation or adverse publicity.
This successful result underscores Lullius Partners’ position as a renowned tax litigation and private wealth law firm in Mallorca and Spain. Our deep expertise in expatriate taxation and tax controversy allows us to protect clients at the highest level—delivering certainty, compliance, and peace of mind even in the most challenging scenarios.
