
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
Our legal and tax specialists provide advice to international private clients with multi-jurisdictional interests, including estate planning and wealth structuring, wills and powers of attorney, domestic and international tax, and residential property.
The Del Canto Chambers team provides our private clients direct access to tax and legal professionals who specialise in helping clients structure their domestic and international affairs in a legally sound and tax-efficient manner. Our goal is to ensure clients’ cross-border wealth is structured effectively for long-term preservation and in compliance with the demands of regulators.
Our client base includes high net worth individuals and their families, often spanning several generations, from a wide number of jurisdictions including continental Europe, the Middle East, and Latin America. Such families and individuals with assets in multiple jurisdictions require specialised advice on the structuring of their affairs as failure to do so can lead to excessive tax on their estates and/ or penalties if they don’t meet their legal obligations.
Understanding family finances requires not only knowing our clients well and identifying their objectives, but also the nature of the investment and current market conditions. This is crucial to implementing the best possible strategy to achieving your tax and legal needs.
Our legal and tax specialists have a multi-jurisdictional understanding of leading issues and a commitment to exceptional client service. There is a large cross-border element to our work and we are accustomed to working with clients’ other advisors in these jurisdictions, often as the orchestrators.
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 Beckham Rule is a special Spanish tax regime for expatriates. It allows qualifying individuals to pay a flat tax rate on employment income and to be treated as non-residents for certain other tax purposes.
Any individual who moves to Spain for professional reasons and has not been tax resident in Spain during the five previous tax years may apply. This includes employees, remote workers, directors, and certain entrepreneurs.
Qualifying income is taxed at a flat rate of 24% up to €600,000. Income exceeding that threshold is taxed at 47%.
You must not have been considered a tax resident in Spain during the five tax years immediately preceding your relocation.
Your move to Spain must be for genuine employment or professional reasons, such as:
Holding an employment contract with a Spanish or foreign companyWorking remotely from Spain under a Digital Nomad Visa
Acting as a highly qualified professional or entrepreneur conducting a business activity in Spain
Serving as a director of a company, provided that—if the company is asset-holding—you hold no more than 25% of its shares
You must apply for the regime within six months of registering with the Spanish Social Security system (Seguridad Social). This deadline is strictly enforced.
The regime applies for a total of six tax years: the year you become a Spanish tax resident and the following five full years.
The regime applies for a total of six tax years: the year you become a Spanish tax resident and the following five full years.
Under the Beckham Rule, all employment and professional income is taxable in Spain, regardless of where it is earned. However, income from non-Spanish sources—such as interest, dividends, investment income, and capital gains—is not subject to Spanish tax.
You are only subject to Wealth Tax and Solidarity Tax on assets located in Spain. Foreign assets are excluded from the Spanish tax base during the six-year period.
Your spouse and dependent children under 25 (or of any age if legally disabled) may also benefit from the regime, provided they meet the requirements and file separate applications.
If you move to Spain to act as a director, you may apply regardless of your shareholding. However, if the company is an asset-holding entity, your ownership must not exceed 25%.
If you cease to be tax resident in Spain before completing the six-year period, you will automatically lose the benefits of the regime. From that point onward, you will be taxed under the general Spanish tax system, which includes progressive rates and worldwide income taxation.
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.
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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