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Private Wealth · 27/07/2026
Private client taxation in Spain: a 2026/27 outlook
What internationally mobile individuals and families with Spanish connections should review this year. The defining feature of the period is not new taxation but new enforcement: a data-rich administration testing residence, regimes and structures against their substance.
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Private client taxation in Spain: a 2026/27 outlook
What internationally mobile individuals and families with Spanish connections should review this year. The defining feature of the period is not new taxation but new enforcement: a data-rich administration testing residence, regimes and structures against their substance.
02The Beckham regime for incoming company directors: a close reading of DGT ruling V1209-25
A recent binding ruling sets out, with unusual clarity, the conditions an incoming director must satisfy to elect the special regime for inbound workers, and where the familiar plan of directing and invoicing through one’s own Spanish company is most exposed. A close reading of DGT consulta V1209-25 of 3 July 2025. Most of what
03Tax Disputes in Spain: A Guide to Tax Controversy and Litigation for International Clients
A comprehensive guide to contesting the Spanish tax authority, for high-net-worth individuals, international families and their advisers, written for readers accustomed to the procedures of HMRC and the IRS. Tax disputes in Spain are also known as tax controversy, tax litigation, and tax dispute resolution; the terms are used interchangeably throughout. Tax disputes in Spain
04Private Client, Private Wealth & Tax Lawyers in Mallorca and Spain
Lullius is a tax boutique with offices in Palma de Mallorca and Madrid. We advise clients across the whole of Spain, and act for international private clients on the questions that follow wealth across borders: Spanish and cross-border tax, private wealth and succession, and tax controversy. Our clients are individuals and families rather than the
05The Migrating Company: Permanent Establishment Exposure Arising from the Beckham Law
A note for founders, executives and investors who have established Spanish tax residence while continuing to direct a business incorporated abroad. An individual relocates to Spain and leaves the structure of his affairs ostensibly intact. The operating company remains incorporated where it always was, in Delaware, in London, in Luxembourg; its clients, its banking and
06Remote work from Spain: when does a home office create a permanent establishment?
The OECD’s November 2025 update to the Commentary on Article 5 sets out, for the first time in nearly a decade, when cross-border remote work creates a permanent establishment. A note on the new framework and how it meets Spain’s traditionally assertive approach. For a foreign company with an employee working from Spain, one question
07Tax Disputes in Spain: A Guide for the Internationally Mobile Taxpayer
An analysis of the Spanish tax review system and its strategic inflection points, written for advisers and clients accustomed to the procedures of HMRC and the IRS. I. Why international taxpayers in Spain find themselves in dispute The taxpayer who relocates to Spain rarely arrives anticipating a confrontation with its tax authority. Yet the Agencia
08The Beckham regime and consulting structures: a recurring pitfall
International professionals who move to Spain, elect the special regime for inbound workers, and invoice their consulting services through a Spanish company they direct, often build the structure most exposed to challenge. A note on why, and on what the Spanish authorities now require. A pattern recurs in practice. An international professional plans to move
09The taxation of trusts in Spain: how the look-through doctrine works in practice
Spain does not recognise the trust, so it taxes through it. A note on the fiscal transparency doctrine of the Dirección General de Tributos, its recent confirmation by the Tribunal Económico-Administrativo Central, and what it means for settlors and beneficiaries who are resident in, or hold assets in, Spain. The trust is one of the
10Substance over form: the AEAT’s new approach to internationally mobile taxpayers
The shift from documentary review to substance-based enforcement in Spanish tax controversy, and what it now asks of internationally mobile individuals and the structures through which they hold their affairs. For most of the last decade, a Spanish tax inspection of an internationally mobile individual was a documentary exercise. The inspector confirmed that returns had
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