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Non-residents holding crypto and Spanish tax (IRNR)
That a non-resident owns or sells crypto-assets does not, by itself, allow Spain to tax them. Spanish non-resident income tax (IRNR) works through connecting factors: only the income the law deems obtained in Spanish territory is subject to it, and double tax treaties may further limit that taxation. With crypto-assets, the difficulty comes earlier: determining where they are located. A portfolio held with a Spanish exchange is not the same as a self-custodied one, and the answer conditions both the IRNR and wealth taxation.
The analyses in this section study when non-residents are subject to Spanish tax, what happens to the crypto estate of those who do not reside in Spain and the scenarios raised by a change of residence.
beckham-law-crypto.md
The impatriate regime (Beckham Law) and the location of cryptocurrencies
Under the special regime of Article 93 LIRPF, the decisive question for crypto-assets is one of location. For self-custody, the DGT takes the view that cryptocurrencies are located in Spain —for IRNR …
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non-residents-crypto-spain.md
Non-residents with crypto-assets and their connection to Spain
Taxing a non-resident who holds crypto-assets calls for avoiding knee-jerk assumptions. The first question is not whether there is an exchange or custodian connected to Spain, but whether the specific …
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