Tax residence

Spanish tax residence: tests under Article 9 of the PIT Act, dual-residence conflicts, residency certificates, treaty tie-breaker rule and evidentiary strategy in tax audits. 4 analyses and 1 FAQ and 1 note, most recent first.

27/05/2026FAQResidence
Frequently asked questions about Spanish tax residence (art. 9 LIRPF)
09/04/2026Note
Criminal Chamber of the Spanish Supreme Court and the tax-residence certificate: a presumption that yields to compelling evidence
09/04/2026TSECLI:ES:TS:2026:1629Residence
The Criminal Chamber of the Spanish Supreme Court rules on the presumption of validity of tax-residence certificates in criminal proceedings
15/07/2025TSSTS 971/2025Residence
The Spanish Supreme Court reiterates the doctrine on the foreign tax residence certificate, but the first tie-breaker rule of the treaty places residence in Spain, the only State where a permanent home is recorded
22/07/2024TSSTS 1392/2024Residence
The Spanish Supreme Court resolves a residence conflict with the United Kingdom involving a remittance-basis taxpayer under the tie-breaker rules (STS 1392/2024)
12/06/2023TSSTS 778/2023Residence
The Spanish Supreme Court sets the value of a foreign tax residence certificate issued for treaty purposes (STS 778/2023)