Willyrex and Vegetta777 appeal Spanish tax rulings, citing Andorra residency

Spanish YouTubers Guillermo Díaz (Willyrex) and Samuel de Luque (Vegetta777) have filed a contentious‑administrative appeal at the National Court (Audiencia Nacional) seeking to annul recent Central Economic‑Administrative Tribunal (TEAC) rulings that require them to pay Spanish taxes for the 2016 and 2017 fiscal years.

Their new legal teams say the TEAC resolutions are “contrary to law and manifestly unjust,” arguing the creators moved their tax residence and centre of professional activity to Andorra years ago and continue to live and work there. Lawyers for the pair contend that Spain’s tax agency (AEAT) itself acknowledged the YouTubers spent more days in Andorra than in Spain during the years under review and that their audiovisual work was produced from studios in the Principality. They add the creators have met Andorran tax obligations.

The teams also say the streamers have paid the disputed assessments to be able to bring the case before the Spanish courts. The AEAT has not disclosed the amounts at issue.

Their lead lawyer, Marc Urgell, told national radio the dispute reflects political motives and a “politicomediatic” approach by Spain’s tax authorities toward high‑profile creators who relocate, rather than a straightforward tax audit. Willyrex has said on his podcast that AEAT acknowledged he had lived in Andorra since 2015 and broadcast from there, yet was nevertheless assessed for 2016 and 2017.

The appeal argues that forcing the pair to pay in Spain would breach principles of international tax law and Spain’s double‑taxation agreements. It forms part of a wider wave of scrutiny by Spanish authorities into content creators who relocated their tax residence to Andorra; several audits have examined whether individuals met residency tests in Andorra or retained a “centre of vital interests” in Spain. Law firms representing groups of creators say they are mounting coordinated legal challenges — one firm has reported representing more than 450 people contesting what it describes as an aggressive Spanish fiscal approach to emigrants.

Legal observers warn the National Court’s decision could set an important precedent. If it upholds the tax agency’s position, emigrants who moved to improve their fiscal situation could face retroactive claims on income generated after their departure. A ruling for the creators could instead be read as protecting professional activity developed outside Spain and reinforcing legal certainty for taxpayers who change residence.

Beyond legal technicalities, the dispute has amplified debate about personal freedom, tax policy and the country’s ability to retain and attract talent. Some commentators argue high tax burdens can incentivise departures of highly skilled professionals and harm competitiveness, while others stress the state’s interest in preventing tax avoidance.

Both Willyrex and Vegetta777 remain prominent online figures with millions of subscribers. The National Court will now examine the appeal against the TEAC rulings; its outcome could influence future disputes over tax residency for digital content creators.