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 Residence in Spain: Beyond Counting Days, Constructing the Evidentiary Narrative
The determination of tax residence in Spain appears, at first glance, to be a matter of mechanical rule application. The legislation offers three apparently objective criteria—the most well-known being the 183-day presence test—which leads many taxpayers to conceive of it as an arithmetical exercise. Practice reveals, however, a considerably more complex reality, particularly for those
32Tax Residence in Spain and Wealth Tax: Foreign Certificates and Tie-Breaker Rules
The High Court of Justice of Catalonia (Tribunal Superior de Justicia de Cataluña, TSJ) has addressed an increasingly common issue in private wealth planning, namely the interaction between a foreign tax residence certificate and Spanish rules on tax residence and Wealth Tax. In judgment 2951/2025 of 3 September 2025, in appeal 1077/2023, the Court confirms
33Spain Tax Treatment of the US Transition Tax for US Citizens Resident in Spain
The Spanish Directorate General for Taxation (Dirección General de Tributos, DGT) has examined the Spanish tax treatment of the US Transition Tax under Section 965 of the Internal Revenue Code in binding ruling V0948-25 of 29 May 2025. The ruling addresses whether a US citizen who is tax resident in Spain may treat the Transition
34Spain Beckham Law and Foreign Partnerships: Tax Treatment of UK LLPs
The interaction between the Spanish expatriate tax regime for inbound workers and holdings in foreign entities treated as transparent for tax purposes has been clarified by the Spanish Directorate General for Taxation (Dirección General de Tributos, DGT) in binding ruling V1372-25 of 21 July 2025. The ruling analyses the Spanish tax implications of the special
35Spain Wealth Tax Shield Extended to Non-Resident Taxpayers: Supreme Court Confirms 60% Limit
In a previous note on the extension of the Spanish wealth tax shield to non-residents, we commented on a judgment by the High Court of Justice of the Balearic Islands that allowed a Belgian taxpayer to reduce his Spanish Wealth Tax (WT) liability by reference to his total income. That decision has now been confirmed
36Spain after the Golden Visa: New Residence Paths
The abolition of residence permits by investment, commonly referred to as Golden Visas, with effect from 3 April 2025 has significantly reshaped the Spanish migration framework. This regime, introduced in 2013, enabled nationals of non-EU jurisdictions to obtain residence in Spain on the basis of qualifying real estate, financial or corporate investments. Going forward, long
37Tax Treatment of RSU Income After Relocation to Spain Under the Beckham Law
Understand Spain’s Beckham Law regime and how deferred RSU awards delivered after relocation are taxed when the underlying work was performed abroad.
38Real Estate Lawyers in Mallorca and Ibiza
Lullius Partners advises international clients on the acquisition, structuring and long-term management of prime property in Mallorca and Ibiza. Through our Private Wealth practice — supported by our US Desk and UK Desk — we deliver integrated legal and tax counsel that combines real estate precision with cross-border sophistication. Our approach is discreet, strategic and deeply technical, ensuring that each property becomes a stable and compliant element within a client’s global wealth architecture.
39Taxation of Foreign Bonuses Under Spain’s Beckham Law
Context and Legal Background Spain’s special tax regime for inbound workers (Article 93 of the Personal Income Tax Law — LIRPF) allows qualifying individuals who relocate to Spain to opt for taxation under the rules of the Non-Resident Income Tax (IRNR), while maintaining their status as Spanish tax residents. The regime aims to attract international
40Taxation of the U.S. Transition Tax for U.S. citizens living in Spain
Taxation of the U.S. Transition Tax for U.S. citizens living in Spain
Page 4 of 12
Stay informed.
Receive selected Lullius briefings on Spanish tax, private wealth and controversy.
Subscribe