In recent years, the Spanish Tax Administration has maintained a restrictive approach toward taxpayers benefiting from the Portuguese Non-Habitual Resident (NHR) regime. Both the Directorate-General for Taxes (DGT) and the Central Economic-Administrative Court (TEAC) have argued that this regime does not entail “full tax liability,” thereby preventing such taxpayers from being recognized as tax residents for the purposes of the Double Taxation Treaty between Spain and Portugal.

Accede al recurso completo

Fuente: EMS