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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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TEAC 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,
32Directors 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
33TEAC 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
34TEAC 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
35Tax 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
36Tax 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
37Spain 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
38Spain 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
39Spain 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
40Spain 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
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