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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.
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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.
22Beckham 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.
23The Legal 500: Tax Disputes Comparative Guide – Spain
The Legal 500: Tax Disputes Comparative Guide – Spain | Lullius
24Inside 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
25Spanish 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.
26Trusts 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
27TEAC Restricts the Deductibility of Foreign Taxes: Effective Economic Activity Abroad Is Required
The Spanish Central Economic Administrative Court narrows the scope of foreign tax deductibility in the Corporate Income Tax The Central Economic Administrative Court (Tribunal Económico-Administrativo Central, TEAC) has delivered an important decision clarifying the limits of deductibility of foreign taxes under article 31.2 of the Spanish Corporate Income Tax Law (Ley del Impuesto sobre Sociedades,
28Directors and the Beckham Law: When a “Holding Company” is, in Reality, a Patrimonial Entity
Analysis of the Resolution of the Regional Economic-Administrative Tribunal of the Balearic Islands of 27 March 2025 The recent Resolution of the Regional Economic-Administrative Tribunal of the Balearic Islands of 27 March 2025 (claim 07/02374/2023) constitutes a pronouncement of singular relevance in the application of the special regime for displaced workers provided for in Article
29TEAC Confirms Imputed Income on Main Residence under the Beckham Law Regime
The Central Economic Administrative Court (Tribunal Económico-Administrativo Central, TEAC) has delivered a landmark decision clarifying a controversial aspect of the Spanish impatriates regime. In Resolution 00/03697/2025/00/00 of 17 July 2025, issued in unification of criterion and classified as doctrine, the TEAC confirms that taxpayers who opt for the special tax regime for workers displaced to
30TEAC Recognises the Right of Non EU Residents to Apply Regional Wealth Tax Rules
The Central Economic Administrative Court (Tribunal Económico-Administrativo Central, TEAC) has delivered a decision of major significance for international private wealth planning involving Spanish assets. In Resolution 00/02959/2023/00/00 of 24 September 2025, classified as doctrine, the TEAC expressly changes its prior administrative criterion and confirms that taxpayers resident in third countries outside the European Union may
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