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Tax · 14/10/2026
Spanish Wealth Tax family business exemption and transparent foreign entities
The DGT denies the family business exemption to the managing partner of a transparent German KG, because the attributed profits dilute her remuneration. A literal and debatable criterion.
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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
22Substance 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
23Data-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
24Spain’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.
25Lullius 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.
26Beckham 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.
27The Legal 500: Tax Disputes Comparative Guide – Spain
The Legal 500: Tax Disputes Comparative Guide – Spain | Lullius
28Inside 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
29Spanish 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.
30Trusts 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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