Summary table

1. That they have not been residents in Spain during the ten tax periods prior to the one in which they move to Spanish territory.

2. That they are not professional athletes.

3. 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.

4. That it does not obtain income that would be classified as obtained through a permanent establishment located in Spanish territory.

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 rate the two specific scales established in article 93 of the Income Tax Law are applied:

  • 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, under the terms provided for in the IRPF Law and the withholdings made on account (including the fees paid on account of IRNR ).
  • The deduction for international double taxation referred to in article 80 of the Personal Income Tax Law