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Directorate-General for Taxes·V5374-26

Carried interest and the Spanish impatriate regime: the DGT confirms that carried interest deriving from points allocated before the move is not taxed in Spain (V5374-26)

Analysis of binding ruling V5374-26 of the Spanish Directorate-General for Taxes (DGT), of 28 July 2026. Carried interest received by an impatriate under article 93 LIRPF, where it derives from points allocated before the move to Spain, is not deemed obtained during the special regime and is not taxed in Spain if it does not derive from a personal activity carried out in Spanish territory. Supplemented by rulings V5360-26 (director of a Spanish holding company) and V1374-26 (remote work for a UK company during the regime).

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Analysis of Spanish case law and administrative doctrine on tax: judgments, TEAC resolutions and binding rulings of the Directorate-General for Taxes, each with its full reference and a link to the source.

Signed technical opinion by Álvaro Crespo García, tax lawyer in Barcelona.

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