Overview
Lawrence Hill, chair of Steptoe's Tax Controversy practice, and Angela Eiref, a tax associate in the firm's New York office, authored an article titled "The Spanish Tax Inquisition" published by Tax Notes on November 19, 2025. The piece examines Spain’s aggressive and, at times, retroactive enforcement against foreign taxpayers who relied on the Special Tax Regime for Impatriates (commonly known as the Beckham Law). The authors detail how the Spanish tax authority has revoked previously granted benefits, imposed steep penalties, and leveraged international information exchange provisions in ways that raise serious concerns about due process, privacy, and compliance with Organisation for Economic Co-operation and Development (OECD) and EU standards.
Read the full article at Tax Notes.
