Case study · Tax Litigation
Defending a cross-border residence position during a Spanish audit
We coordinated the factual, treaty and procedural defence of an internationally mobile individual whose tax residence was challenged in Spain.
The audit examined travel, homes, family connections, investments and business interests over several years.
Because some facts could be interpreted differently in each country, the client needed one account that remained accurate and consistent across authorities.
The challenge
- Incomplete travel and location records.
- Competing domestic residence rules and treaty tie-breakers.
- Evidence held by banks, businesses and advisers overseas.
- Parallel tax and penalty exposure.
Our approach
Technical precision, focused on the client.
Evidence matrix
We indexed objective evidence by year and by residence criterion, identifying gaps before responding.
Treaty coordination
Counsel in the other country validated local filings and the interpretation of residence under the applicable treaty.
Consistent narrative
Submissions, witness material and technical arguments were built around a single chronology rather than isolated day counts.
The outcome
The client presented a coherent residence defence supported by contemporaneous evidence and coordinated overseas advice.
The same record was structured for use in any later administrative or judicial appeal, avoiding a costly reconstruction at a later stage.
Residence is an evidential question as much as a legal one. A clear chronology gives the law something reliable to work with.
The Lullius approach
