The Spanish Supreme Court Opens the Door for Non-Residents to Benefit from the Wealth Tax Limitation

The Supreme Court (TS) has recently issued two key ruling – STS 4849/2025 (of 29 October) and STS 4846/2025 (of 3 November) – which entail a considerable tax benefit for non-residents in Spain subject to the Spanish Wealth Tax (impuesto sobre el patrimonio).

The OECD Defines New Permanent Establishment Rules for Remote Working

• Essential new guidance for multinationals with remote workforces
• Introduction of the “50% rule” and the “commercial reason” test to determine the existence of a permanent establishment for the employer in the employee’s country of residence.

Beckham Law and Directors of Holding Companies: Practical Analysis of Binding Decision V1068-25

Introduction The special regime regulated under Article 93 of Spanish Law 35/2006 on Personal Income Tax (LIRPF) —commonly known as the “Beckham Law”— allows individuals relocating to Spain to be taxed as Spanish tax residents but under the rules of the Non-Resident Income Tax (“IRNR”), provided that certain conditions are met. In practice, this means […]

BYD and opportunities for foreign suppliers in Spain: A strategic guide to investment

Tax Alert: Electronic Notifications to Foreign Entities in Spain

The Spanish Central Tax Appeal Board (TEAC) has confirmed that foreign entities operating in Spain, even without a permanent establishment in Spain, are required to communicate electronically with the Spanish Tax Authorities. In the matter in question, a Dutch company had transferred a property in Spain and disputed the validity of an electronic notification sent to […]

Spain Extends Paid Leave for Birth, Adoption, Guardianship, Foster Care and Childcare for Minors

On 29 July, Royal Decree-Law 9/2025 of the same date on the extension of paid leave for birth and care was published in the Spanish State Gazette. This Royal Decree transposes Directive (EU) 2019/1158 of the European Parliament and of the Council of 20 June 2019 on the work-life balance of parents and carers, repealing Council Directive 2010/18/EU. Furthermore, it introduces a number of amendments to Spanish legislation: the Workers’ Statute in its version given by Royal Decree 2/2015 of 23 October, the Basic Statute for Public Employees, in its version given by Royal Decree 5/2015 of 30 October, and the General Social Security Law, in its version given by Royal Decree 8/2015 of 30 October.