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Client (Spanish) moved to Ireland in 2012 and started work for Irish Company early 2013. Moved back to Spain May 2016 but continued to work for same Irish Company under same Irish contract. Must spend approximately 4/6 weeks per year in Ireland only. Can assume Resident in Spain for 2017 under Residency test (>183 days there) and under Article 4 of DTA in Spain as home & family there. Trying to interpret Article 15. As he is Spanish Resident in 2017 is it saying the salary is taxable in Spain only? Does the Irish employer then need to apply for a PAYE exclusion order? Does the nature of the work matter (i.e. it is for benefit of Irish Company) or is it just where it is exercised (i.e. Spain)? Thanks

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Asked on 7 June 2017 11:07 am