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.

The Spanish Government Approves the Draft Bill for the Trainee Statute

On 4 November 2025, the Spanish Council of Ministers approved, the draft bill for the Statute for people in non-employment-related practical training (“Trainee Statute”), proposed by the Spanish Ministry of Labour and Social Economy. The draft bill was born from agreements with the most important Spanish trade unions (CCOO and UGT). It seeks to guarantee equal opportunities and prevent the use of people in non-employment-related practical training in companies from becoming a means of job insecurity/use of “false interns”.

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 […]