Comparative table

SPECIAL TAX REGIME APPLICABLE TO WORKERS DISPLACED TO SPANISH TERRITORY

Conditions and requirements for its application
FROM JANUARY 1, 2015 (Article 93 of the Law of PIT, wording given by Law 26/2014)	UNTIL DECEMBER 31, 2014 (Article 93 of the Law of PIT, wording given by Law 26/2009)
That they have not been residents in Spain during the ten tax periods prior to the one in which they move to Spanish territory. That they are not professional athletes. That the transfer to Spain took place as a result of any of the following circumstances: From an employment contract. From the acquisition of the status of director of an entity in whose capital he does not participate or, otherwise, when the participation in the same does not determine the consideration of a related entity in the terms provided for in article 18 of the Corporate Tax Law. That does not obtain income that would be classified as obtained through a permanent establishment located in Spanish territory	From January 1, 2007 to January 1, 2010 That they have not been residents in Spain during the ten years prior to their new move to Spanish territory. That the transfer to Spanish territory occurs as a result of an employment contract. That the work is actually carried out in Spain. That said work is carried out for a company or entity resident in Spain or for a permanent establishment located in Spain of an entity not resident in Spanish territory. That the income from work derived from the aforementioned employment relationship is not exempt from taxation by the Non-Resident Income Tax. From January 1, 2010 to December 31, 2014 In addition to the above requirements, the following: That the expected remuneration derived from the employment contract in each of the tax periods in which this special regime is applied does not exceed the amount of 600,000 euros per year.

SPECIAL TAX REGIME APPLICABLE TO WORKERS DISPLACED TO SPANISH TERRITORY

Content: rules for determining tax debt
FROM 1 JANUARY 2015 (Article 93 of the Personal Income Tax Law, as amended by Law 26/2014)	UNTIL DECEMBER 31, 2014 (Article 93 of the Law of PIT, wording given by Law 26/2009)
The debt is determined according to the rules of the IRNR with the following specialties: All work income obtained by the taxpayer during the application of the special regime is deemed to have been obtained in Spanish territory. The income obtained by the taxpayer in Spanish territory during the calendar year is taxed cumulatively, without any offsetting being possible between them. To determine the full quota, the two specific scales established in article 93 of the Law of the PIT: A scale for the part of the base corresponding to the income referred to in Article 25.1. f) of TRLIRNR (dividends, interest and capital gains). A scale for the part of the base corresponding to the rest of the income. The differential rate will be the result of reducing the full tax rate by: The deduction for donations, in the terms provided for in the Law of PIT and the withholdings made on account (including the amounts paid on account of the IRNR). The deduction for international double taxation referred to in article 80 of the Law of the PIT	The debt is determined according to the rules of the IRNR with the following specialties: Taxpayers are taxed separately for each total or partial accrual of income subject to tax, without any offsetting being possible between them. The taxable base of each income is calculated for each of them according to the provisions of TRLIRNR . The full rate is obtained by applying to the taxable base the tax rates established by article 25.1 TRLIRNR in the version in force on 31-12-2014 (general rate: 24.75%; dividends, interest and capital gains: twenty-one%). The differential rate is the result of reducing the full tax rate by the deduction for donations, in the terms provided for in the Law of PIT and the withholdings made on account. The fees paid on account of IRNR are also deductible.