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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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Exit Tax Risks: Effective Strategies for Individuals Relocating to or from Spain
For high-net-worth individuals (HNWIs), entrepreneurs, executives, and professionals with international careers, relocating across borders is more than just a lifestyle decision—it involves significant tax implications, chief among them being the Exit Tax. These taxes, imposed on unrealized gains when individuals change their tax residency, are increasingly relevant in global mobility decisions. Jurisdictions such as the
52The Spanish Tax Treatment of Trusts: A Transatlantic Perspective
Introduction: When Two Legal Worlds Collide For decades, the trust has been the Swiss Army knife of Anglo-Saxon wealth and estate planning. Ubiquitous in the United States and United Kingdom, it is the cornerstone of family office structuring, private client advice, and asset protection. Yet, for individuals or families with links to Spain—whether as residents,
53Why UK HNWIs Are Moving to Mallorca and Ibiza
Lullius Partners is a top-ranked boutique tax law firm based in Mallorca, specialising in international tax advice and private wealth management for UK families, entrepreneurs, and high-net-worth individuals (HNWI). Our dedicated UK Desk provides bespoke cross-border solutions, including strategic tax planning, Beckham Law applications, Digital Nomad Visas, and comprehensive support for relocating your residence and wealth to Mallorca or Ibiza. As expert UK tax lawyers in Spain, we ensure seamless integration of UK and Spanish legal frameworks, enabling our clients to protect and optimise their international wealth securely and efficiently.
54Case Study: Successful Relocation of a U.S. HNWI Family to Spain
Lullius Partners was approached by a high-net-worth individual (HNWI), senior executive at a prominent U.S.-based multinational group, who was planning to relocate to Spain with his spouse and children. The family had chosen Barcelona as their new residence and intended to establish a long-term base in Spain for both personal and professional reasons. Given the
55Case Study: Successful Closure of a Tax Audit on Beckham Law Application
Lullius Partners achieves the dismissal of all findings in a complex tax audit regarding the application of Spain’s Beckham Law for a high-net-worth individual and his holding company. The Challenge In early 2025, an international executive relocating to Spain, together with his Spanish holding company, faced an intensive tax audit initiated by the Spanish Tax
56Case Study: Lullius Partners Overturns AEAT Tax Enforcement and Liability Derivation
At Lullius Partners, we are proud to share another example of our effective defence and technical expertise in high-stakes Spanish tax litigation. Recently, our Private Wealth and Tax Litigation team successfully secured the annulment of two enforcement orders (Providencias de Apremio) and two subsidiary liability derivation files (Derivación de Responsabilidad Tributaria Subsidiaria) issued by the
57Lullius Partners: Mallorca’s Leading Private Wealth & Tax Lawyers for International Clients
In a world where private wealth management and cross-border tax planning are becoming increasingly complex, the demand for truly specialised, technically excellent legal counsel has never been greater. Lullius Partners, a top-ranked boutique law firm based in Mallorca, Spain, stands at the forefront of this evolution—offering market-leading expertise to high-net-worth individuals, expatriates, family offices, and
58Tax Authorities Crack Down on Artificial Employment Contracts Under the Beckham Law
Attracting international talent is a cornerstone of Spain’s economic and social strategy. Over the past two decades, the so-called “Beckham Law”—the Spanish impatriate tax regime—has provided an attractive, preferential tax framework for highly skilled professionals and executives relocating to Spain. But as with any special tax regime, its benefits come hand-in-hand with strict eligibility criteria
59Crypto Under Scrutiny: Spain’s Tax Authorities Intensify Tax Audits
Crypto, Tax Audits and a New Era of Scrutiny If you thought crypto was still flying under the radar in Spain, think again. The Spanish Tax Agency (AEAT) has dramatically upped its game in 2025, launching a wave of inspections and information requests aimed squarely at anyone who invests in or provides services related to
60Relocating to Spain as an Executive? New DGT Ruling Clarifies Access to the Beckham Law
The increasing mobility of international talent and the strategic decisions of multinational groups continue to shape the landscape of tax planning in Spain. In this context, the so-called “Beckham Law” (Article 93 LIRPF) remains a cornerstone for attracting senior executives and key professionals to Spanish subsidiaries. However, the regime is neither automatic nor risk-free; its
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