Spanish YouTubers Appeal €3M Tax Bill Despite Andorran Residency

Spanish YouTubers Guillermo Díaz (Willyrex) and Samuel de Luque (Vegetta777) are appealing decisions by Spain's Central Tax-Economic-Administrative Tribunal (TEAC) that require them to pay nearly €3 million in taxes to Spain for 2016 and 2017, despite their Andorran residency during those years.

The TEAC recently rejected their initial challenges, upholding claims by Spain's State Tax Agency (AEAT, or Hacienda) for €1.25 million from Willyrex and €1.7 million from Vegetta777. Hacienda argues the creators' income sources remain rooted in Spain, primarily through Vizzmedia Online—a Spanish agency that manages their advertising contracts and campaigns. Under personal income tax rules, this constitutes their "centre of economic interest" in Spain, overriding their physical residency and Andorran tax domicile.

The YouTubers, represented by lawyers Marc Urgell and Iñaki Picaza, have now lodged an administrative lawsuit with Spain's National High Court (Audiència Nacional). Their legal team calls the TEAC rulings "contrary to law and manifestly unjust," noting that AEAT records confirm the pair spent more days in Andorra than Spain in the disputed years. They emphasize that live streams and other content production occurred from studios in the Principat, with online work accessible globally rather than tied to a Spanish base.

The dispute centres on whether digital creators' tax liability follows residency or income origins. Hacienda's stance could extend to other Andorran residents using Vizzmedia, including El Rubius, Cristinini, DJMaRiiO, Paula Gonu, and Nil Ojeda.

Though litigated in Spanish courts, the outcome holds significant weight for Andorra's residency model, which attracts professionals with its lower taxes. A win for Hacienda might deter high-profile Spanish relocations without physical businesses in Spain, potentially redefining fiscal rules for remote digital work.