Blog, News
Insights
Clear thinking on the Spanish tax questions affecting internationally mobile people, private wealth and cross-border business.
Lullius briefings
Our writing focuses on the decisions, risks and procedural moments that matter in practice.
Tax · 20/09/2026
The Beckham Law: changing jobs, cutting hours or working remotely for a foreign employer without losing the regime
In ruling V1374-26 the DGT accepts that an inbound worker may reduce the hours of the job that prompted his move, work remotely for a British company and later take up the directorship of a Spanish company without losing the Beckham Law.
Read the briefing116 insights
Tax 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
12Private 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
13The 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
14Remote 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
15Tax 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
16The 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
17The 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
18Substance 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
19Data-Driven Tax Audits: How Spain’s Tax Authority Selects Risk and What It Means for HNWI
The way in which the Spanish Tax Agency (Agencia Estatal de Administración Tributaria, “AEAT”) decides whom to audit has changed profoundly. The selection of taxpayers no longer rests on manual or isolated criteria but on the mass processing of information, the systematic cross-checking of sources and, increasingly, on artificial intelligence tools that detect inconsistencies and
20Spain’s Controlled Foreign Company Rules: The Hidden Risk in International Structures
The internationalisation of wealth and business has made the use of foreign entities by Spanish tax residents entirely routine. International holding companies, investment vehicles, asset-holding structures and companies incorporated in jurisdictions such as the United Arab Emirates, Estonia, Luxembourg, Ireland or the United States are now an ordinary feature of many family and corporate arrangements.
Page 2 of 12
Stay informed.
Receive selected Lullius briefings on Spanish tax, private wealth and controversy.
Subscribe