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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.

120 insights

Blog, News14/06/2026
21

The 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

Blog, News13/06/2026
22

Substance 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

Blog, News01/06/2026
23

Data-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

Blog, News31/05/2026
24

Spain’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.

Blog, News15/05/2026
25

Lullius Contributes to the Chambers Tax Controversy Global Practice Guide – Spain

Lullius contributes the Spain chapter of the Chambers Tax Controversy Global Practice Guide 2026, on AEAT substance-based enforcement and Beckham Law audits.

Blog, News15/05/2026
26

Beckham Law Audits and the AEAT’s Substance Shift in 2026

Lullius’s analysis of the AEAT’s substance-based enforcement, Beckham Law revocations and permanent establishment audits, from our Chambers 2026 chapter.

Blog, News13/03/2026
27

The Legal 500: Tax Disputes Comparative Guide – Spain

The Legal 500: Tax Disputes Comparative Guide – Spain | Lullius

Blog, News17/02/2026
28

Inside a Beckham Law Tax Audit: Simulation, Interposed Entities, and Penalties

What the AEAT’s Assessment Files Actually Reveal About Enforcement in 2025 Lullius Partners | February 2026 At Lullius Partners, we defend Beckham Law positions across Spain. We are routinely instructed in live inspections, and we review the assessment files that result from them. This article draws directly on anonymised inspection materials from cases in which

Blog, News25/12/2025
29

Spanish Tax Audits of the Beckham Law, What the AEAT Is Reviewing in Practice

How the AEAT audits the Beckham Law in practice. Simulation, permanent establishment, place of effective management, evidence expectations, and defence strategies for impatriates.

Blog, News23/12/2025
30

Trusts and Wealth Taxation: The Legal Limits of Taxing Fragmented Ownership

The renewed debate on wealth taxation is often framed in terms of fairness, redistribution and political resolve. Yet from a legal perspective, the central difficulty of taxing wealth lies elsewhere. The true challenge is not whether wealth should be taxed, but how wealth is defined, attributed and located within legal systems that conceptualise property in

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