International tax law at the intersection of Spain, the US, the UK and Europe. Stock options. Beckham Law. Trusts. Permanent establishment. Private client advice — not a generalist service — in English and Spanish.
Most Spanish advisors handle domestic tax. Most US or UK advisors don't know Spanish law. The gap between them is where expensive mistakes happen.
You're a US citizen or UK national living in Spain, filing a Spanish declaración de la renta while the IRS or HMRC still expects a full return. FBAR. FATCA. The Spain-US Double Tax Treaty. The saving clause that prevents most treaty benefits for US citizens. The intersection is technically demanding and almost always mis-handled by advisors who only know one side.
ISOs, NQSOs, RSUs, phantom shares, carried interest. When equity granted under a US or UK plan vests or is exercised while you are a Spanish tax resident, the interaction with IRPF, the 30% reduction for irregular income, and the applicable double tax treaty requires planning — not just filing. The difference can be six figures on a single vesting event.
Your company has employees working remotely from Spain. Your CEO recently moved to Marbella. Your board meetings happen in Mallorca. Any one of these facts could create a establecimiento permanente — a permanent establishment — subjecting your foreign company to Spanish corporate income tax at 25%, VAT registration and payroll withholding obligations. BEPS Action 7 has made the AEAT more aggressive, not less.
The régimen especial de tributación de impatriados offers a 24% flat rate for up to six years. We assess eligibility, prepare the Modelo 149 application, and plan the interaction with your home country tax obligations.
Learn more →The 183-day rule is the start, not the end, of the analysis. Habitual residence, centre of vital interests, treaty tie-breakers under the Spain-US, UK-Spain and Germany-Spain DTAs. We handle the full position including exit tax from your prior country.
Learn more →IRPF treatment of ISOs, NQSOs, RSUs and phantom shares at exercise. The 30% rendimientos irregulares reduction, its €300,000 cap, FATCA reporting for US citizens, and double-taxation planning across US, UK and Spanish tax systems.
Learn more →Spain does not recognise the trust as a legal entity — but it taxes trust income with precision under Art. 91 LIRPF. US revocable trusts, UK discretionary trusts, Liechtenstein foundations. Model 720 obligations. Pre-residency restructuring.
Learn more →Fixed place of business, agency PE, home office risk. BEPS Action 7. We assess PE exposure for foreign companies with Spain-based employees, quantify the corporate tax and VAT consequences, and advise on compliant structuring.
Learn more →AEAT comprobación limitada and full actuaciones inspectoras. Late Model 720 filings, Beckham Law errors, non-resident rental income, crypto, PE allegations. Penalty reduction strategies. Appeals to TEAR, Audiencia Nacional and the Supreme Court.
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Jacob Salama is a registered Spanish lawyer (abogado colegiado) dedicated to private client international taxation for clients with connections to Spain. He advises US, UK, German, Norwegian, Austrian and Swiss nationals on every dimension of their Spanish tax position — from Beckham Law applications to AEAT inspection defence.
Unlike most Spanish tax advisors, Jacob works directly in English and Spanish. His clients are not passed to junior staff. Every engagement involves direct access to a lawyer who understands both the Spanish legal system and the tax systems of your home country.
A clear, structured process — from the initial analysis of your cross-border position to full representation before the Spanish tax authority.
We review your situation together via video call. No obligation. We tell you honestly whether we can help and what it will cost.
A full written analysis of your Spanish tax position, your home-country obligations, treaty interaction and any reporting requirements.
A clear roadmap: Beckham Law application, treaty elections, pre-residency planning, Modelo 720 filing, withholding optimisation — whatever your situation requires.
Annual returns, tax authority queries, inspections, appeals. We remain your Spanish tax counsel for as long as you need.
Every legislative change to Art. 93 LIRPF, from the 2004 introduction through the 2023 Startup Law overhaul — and what each change means in practice.
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Beckham Law taxpayers are not recognised as Spanish tax residents for DTA purposes. The implications for US citizens, UK nationals and German expats are significant — and frequently misunderstood.
Read article →The digital nomad subcategory introduced by the 2022 Startup Law — remote work for a foreign employer, the International Remote Work Visa, and the irrebuttable presumption of causal link.
Read article →US, UK, Dutch and other international clients on Beckham Law, FATCA, trust planning and AEAT defence.
* Testimonials are genuine client feedback collected via email and shared with permission. Names and identifying details have been anonymised.
I relocated from San Francisco to Barcelona on a digital nomad visa and assumed my employer's HR team had the Spanish tax side covered. They did not. Jacob identified that the Beckham Law application window was about to close and filed the Modelo 149 with less than two weeks to spare. His analysis of how the regime interacted with my ESPP and RSU grants — and what that meant for my US federal return — was genuinely impressive. The dual-country complexity is real, and Jacob is one of very few advisers who understands both sides without simplifying either.
We moved to Andalusia as a family and were beneficiaries of a UK discretionary trust settled by my father. The question of how Spain would treat trust distributions — and whether the trust assets triggered Modelo 720 obligations — was something our UK solicitors could not answer. Jacob produced a detailed written analysis of the Art. 91 LIRPF attribution rules, the treaty position, and a practical restructuring recommendation for our pre-residency window. The memo was thorough, clearly written, and has served as the reference document for our ongoing compliance.
I received an AEAT notification challenging my tax residency position — they were asserting I had been a Spanish resident for two years prior to the date I had self-declared. The potential assessment, including interest and penalties, was substantial. Jacob took over immediately, reviewed the AEAT's reasoning, and built a careful factual and legal response based on the tie-breaker provisions of the Belgium-Spain treaty. The comprobación was closed without an assessment being raised. I was genuinely impressed by the precision of his argument.
Select a time that works for you. No obligation — we will tell you honestly what your situation requires and what it will cost.
Describe your situation and we will come back to you — usually within one business day.
Jacob responds personally to every enquiry in English and Spanish. First consultation is always free of charge.
Legal Disclaimer: The information on this website is provided for general informational purposes only. It does not constitute legal or tax advice and does not create a lawyer-client relationship. Tax law is subject to frequent change and its application depends entirely on individual circumstances. Jacob Salama (Salama Legal SLP, Colegiado nº 11.294 ICAMálaga) is a registered Spanish lawyer and is not authorised to provide US, UK or German legal advice. Always obtain specific professional advice before taking any action.