Counting days: Shakira’s Spanish tax nomad case

In the UK a day for tax residency purposes is counted if the individual is in the UK at the end of the day (that is midnight).

Spain is different. A day in Spain can be any length. As we shall explain it is not counted as 24 hours nor does it include an overnight stay.

International tax advisers must be aware of the Spanish tax residency rules especially if according to the latest data almost one-third of the UK population spends at least one day a year in Spain.

In September 2022 the Spanish tax authorities referred Shakira to the public prosecutor claiming income and wealth tax evasion for years ending 2012 to 2014 as she did not report earnings of €34.9m with allegations of tax evasion totalling €14.5m more than €23m in fines and an eight-year prison...