Notes

Short notes on recent Spanish tax developments.

05/05/2026Note
Home entry under article 113 of the LGT: the court order must give specific reasons for digital access
02/05/2026Note
Law 49/2002 regime and non-resident foundations: prior election and formal notification, no shortcuts
28/04/2026Note
Video-game virtual currency and VAT: the CJEU confines the Hedqvist doctrine and returns the transaction to the general regime
25/04/2026Note
VELCRO: no beneficial owner, neither the Directive exemption nor the reduced treaty rate
22/04/2026Note
Beckham regime: the prior five-year period is measured in tax residence, not in physical presence
16/04/2026Note
Family business: negative income from other economic activities does not enter the denominator of the 50%
09/04/2026Note
Criminal Chamber of the Spanish Supreme Court and the tax-residence certificate: a presumption that yields to compelling evidence
30/03/2026Note
Penalties under article 171.One.4 of the VAT Act for reverse charge: the proportionality doctrine stands
25/03/2026Note
Notification at the tax domicile despite the designation of a representative: the TEAC sets a unified criterion under the purpose-achieved rule
11/03/2026Note
Mixed holding and intragroup transfer of shares: differentiated sector under VAT, save an autonomous economic unit
11/03/2026Note
Tax self-assessment: rectification under article 120.3 of the LGT as the ordinary review channel
02/03/2026Note
International remote work from Spain: the Beckham regime opens, but the risk zone is the employer
27/01/2026Note
Restructuring into a holding: prior subsidiary remuneration does not count towards the 50% family-business test
27/01/2026Note
Total demerger to prepare generational handover: valid economic reason under the FEAC regime