
Double Taxation Dispute Lessons: Carulla Font v HMRC
The recent case of Carulla v HMRC [2025] EWHC 3057 serves as a clear example of the high stakes involved in a double taxation dispute. The legal issue was twofold: first, whether HMRC
Individuals eligible for this visa include those with higher education or equivalent professional experience of at least three years, graduates or postgraduates from universities and business schools, and individuals with degrees in regulated professions requiring degree homologation. To be eligible you must be a manager overseeing a sizable team within a company, an individual in a technical or specialized role, or a graduate/postgraduate from a reputable university or business school.
The minimum salary requirement for a management position is €54,142 per year, and for a non-management position, it is €40,077 per year.
The application process involves submission via the Unit for Large Companies and Strategic and Economic Sectors (UGE-CE). Required documentation includes a passport-style photo, original passport, background check, application form, fee payment proof, funds proof, qualifications proof, job description, and CV.
The visa also allows free movement within Schengen member countries and permits obtaining residency for spouses, children and dependent adult children. This residence permit allows them to work in Spain as well.
Del Canto Chambers’ dual-qualified, multilingual tax lawyers have handled over 500 complex cases from Europe, the Middle East, Latin America, and Asia. Discerning London-based and international clients, corporations, solicitors, and tax advisors count on our expertise.
You can more about what clients have to say, about working with Del Canto Chambers here below.
The Highly Qualified Professional visa is a type of visa that allows individuals with specialised skills and higher education to work and reside in Spain.
Individuals eligible to apply for this visa are those with higher education, equivalent professional experience of at least three years, graduates or postgraduates from recognised universities and business schools, as well as those with degrees in regulated professions that require degree homologation.
The purpose of the Highly Qualified Professional visa is to attract specialised and qualified talent to Spain to contribute to the economic and business development of the country.
This visa offers several benefits, such as the possibility to reside and work legally in Spain, freedom of movement within the Schengen Area, the option to obtain residence for dependent family members and the opportunity to change employers without the need to apply for a new visa. In addition, it can lead to obtaining permanent residence in Spain?
The validity of the residence permit will be for 3 years, or equal to the duration of the contract if it’s less than 3 years. This residence permit is renewable for two years, and afterward, permanent residence can be requested.
Del Canto Chambers has a specialised team ready and eager to support you to apply for Spanish nationality. If you are interested in applying and would like to know if you are eligible, we would be delighted to help you.
Del Canto Chambers specialists are constantly up to date with new legislative changes and aware of any Spanish tax and legal implications. Contact our Spanish legal and tax specialists to find out the best tax planning and corporate structures in your circumstances.
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At Del Canto Chambers we are always sharing our knowledge and act as an active voice across different media. The following articles and news are related to and relevant for Real Estate Sale & Purchase and Spanish Tax Law.

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