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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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Tax 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.
42Real 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.
43Taxation 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
44Taxation 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
45Spanish Taxation of Trusts under the Beckham Law: Wealth and Inheritance Implications
Spanish Taxation of Trusts under the Beckham Law: Wealth and Inheritance Implications
46Case Study: Securing Beckham Law Eligibility in Spain
In this case, our firm successfully overturned a proposed denial by the Spanish Tax Agency (AEAT) concerning access to the Beckham Law. The AEAT had argued that our client, a senior executive relocating to Spain in 2025, had already been a Spanish tax resident within the previous five years, relying on municipal registration, utility bills, and the purchase of a car in Spain. We demonstrated that these indicia were legally insufficient to establish tax residence. Through extensive documentation—including employment contracts, social security contributions, tax returns, and certificates of fiscal residence in the Czech Republic—we proved that the client’s professional, family, and economic life had remained firmly abroad until 2025. We further highlighted that, even in a hypothetical conflict, the Spain–Czech Republic Double Tax Treaty would allocate residence to the Czech Republic. The AEAT accepted our submissions, confirmed the client’s eligibility, and issued the certificate granting application of the special regime. This outcome underscores the importance of rigorous legal strategy and cross-border expertise in safeguarding access to the Beckham Law.
47New Tax Exemption for Family Money Gifts in Mallorca
On 27 July 2025, the Balearic Islands enacted a major reform in their regional inheritance and gift tax regime through Decree-Law 4/2025, of 26 July, published in the BOIB (Official Gazette of the Balearic Islands). As a result, monney gifts between parents and children, grandparents and grandchildren, spouses, or long-term partners are now 100% tax-exempt
48No Exit Tax on Crypto Under Spanish Law
As the international mobility of high-net-worth individuals (HNWIs) becomes increasingly common, the tax implications of relocating one’s tax residence are coming under closer scrutiny. This is especially relevant for individuals holding assets with substantial unrealised gains — such as cryptocurrencies — who are considering relocation to low-tax jurisdictions. In this context, the Spanish Tax Authority
49Beckham Law & Employer of Record (EOR) in Spain: Tax Risks and Compatibility
The Special Tax Regime for Expatriate Workers under Article 93 of the Spanish Personal Income Tax Act (“Beckham Law”) The special tax regime for expatriate workers relocating to Spanish territory—commonly known as the “Beckham Law”—was initially introduced by Law 62/2003 of December 30, with the explicit aim of attracting highly qualified talent by offering competitive
50Holding Structures in Spain under Scrutiny after Recent TEAC Rulings
In recent years, Spanish tax authorities have intensified their scrutiny of corporate restructuring operations involving holding companies—particularly within family-owned groups—placing a sharp focus on the special tax neutrality regime known as FEAC (Fiscal Neutrality Regime for Corporate Restructurings). The year 2024 was particularly significant, as the Spanish Central Economic-Administrative Court (TEAC) issued several decisions establishing
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