— Analysis & judgement

Tax criterion for cross-border operators

Technical analysis of international tax, Spanish tax law and fiscal planning for expats in Spain.

18 articles 3 languages 6 areas ES · DE · US jurisdictions
— Areas
— Articles
18 · 2026
— 05

Double Tax Treaties: how to read a DTT without assumptions

A DTT does not exempt: it allocates taxing power between two states. Reading it well requires treaty residence (art. 4), permanent establishment (art. 5), the art. 6–22 distribution and the art. 23 elimination methods. Operational guide.

— 06

Digital nomads in Spain: tax planning before crossing the border

Law 28/2022 opened a specific visa for international remote workers, but Spanish tax residence is triggered by days, by economic centre or by family. Operational guide to align visa, tax regime and Social Security before arrival.

— 07

ETVE: the Spanish holding regime for foreign shareholdings

Spain's Foreign-Shareholding Holding Entity regime applies exemption to dividends and capital gains from non-resident subsidiaries (art. 21 LIS) and allows onward distribution to non-resident shareholders without Spanish withholding. Operational guide to requirements, substance and ATAD3 exposure.

— 08

Crypto-asset taxation in Spain 2026

Crypto-to-crypto swaps, staking, mining, airdrops and NFTs under Spanish personal income tax, wealth tax and the 721 filing obligation. Operational guide for Spanish tax residents with diversified portfolios.

— 09

Beckham Law 2026: international professionals

Eligibility after Law 28/2022, the Year-One Gap, Form 149, family extension and the TEAC vs TSJ Madrid split on imputed property income. Operational guide for the international professional relocating to Spain.

— 10

Self-employed vs. Beckham + LLC: which fits

Tax comparison for independent professionals moving to Spain: ordinary self-employed regime versus Beckham channelled through a foreign LLC/Ltd. Quota gap, economic substance, Scheinselbstständigkeit and six-year horizon.

— 11

Registering a foreign employer in Spain without PE

Step-by-step procedure for a non-resident entity to employ a worker in Spain without creating a Permanent Establishment: N-starting tax ID, foreign-employer social security code, Form 036, Form TA.6, anti-PE clauses and fiscal representation.

— 14

Filing the 2025 Spanish tax return with ChatGPT: technical risk analysis

ChatGPT has no access to your AEAT data, operates on a frozen knowledge cut-off, and carries no professional liability. Technical analysis of the six structural failures that make large-language models unsuitable for filing the 2025 Spanish IRPF return.

— 16

Spain 2025 housing deductions: State, regional and energy efficiency

Technical catalogue of housing-related deductions in the 2025 Spanish IRPF return: transitional regime under Article 68.1 LIRPF for purchases before 2013, regional rent deductions, energy-efficiency works, electric vehicles and charging-point installation.

— 18

The eight AEAT draft errors we detect every campaign

The Spanish Tax Agency's pre-filled draft is a starting point, not an optimised return. We review the eight most frequent errors we detect each campaign: regional deductions left out, two-payer scenarios miscalibrated, foreign brokers unreported, family minimums under shared custody.

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