La noción de centro de intereses económicos en la determinación de la residencia fiscal: RTEAC de 19 de diciembre de 2022, RG. 00/04837/2019

Abstract

The TEAC, in its recent Resolution of December 19, 2022, addresses the configuration of the concept of center of economic interests for the purpose of determining the tax residence in Spain of an individual. In a case where the possible alternative tax residence was located in Andorra, the TEAC addresses the issues traditionally debated around this notion: the weighting
of income and wealth, the importarme of the composition of wealth, the jurisdictions with which income and wealth located in Spain should be compared and the burden of proof in case of dispute.