Willyrex and Vegetta777 appeal Spanish tax orders, citing Andorra residency

Spanish YouTubers Guillermo Díaz (Willyrex) and Samuel de Luque (Vegetta777), both resident in Andorra, have lodged a contentious‑administrative appeal with Spain’s National Court (Audiencia Nacional) against recent rulings by the Central Economic‑Administrative Tribunal (TEAC) ordering them to pay Spanish taxes for the 2016 and 2017 fiscal years.

Their lawyers, Marc Urgell and Iñaki Picaza, say the TEAC resolutions are “contrary to law and manifestly unjust.” The defence contends the creators moved their tax residence and centre of activity to Andorra years ago, that they spent more days in Andorra than in Spain during the years under review, and that their professional work is carried out from studios based in the Principality — points the legal teams say the Spanish Tax Agency (Agencia Estatal de Administración Tributaria, AEAT) has acknowledged.

The amounts the tax authorities are seeking have not been disclosed. Legal representatives note that, given the streamers’ multimillion‑euro incomes and the gap between Spanish marginal rates — around or above 40% — and Andorra’s top rates of about 10%, any assessment could be substantial.

The appeal asks the National Court to annul the TEAC resolutions. Defence lawyers argue that ordering their clients to pay taxes in Spain would breach basic principles of international tax law and Spain’s treaties to avoid double taxation, since the creators say they live and work from Andorra and comply with Andorran tax obligations.

The dispute comes amid increased scrutiny by Spanish tax authorities of high‑profile content creators who changed their tax residence to Andorra. Audits in several cases have questioned whether individuals met the 186‑day residency requirement in Andorra or retained their “centre of vital interests” in Spain — factors that can determine tax residence under Spanish law.

The legal move also joins a broader wave of challenges coordinated by law firms handling multiple complainants. Amsterdam & Partners says it represents more than 450 people contesting what it describes as a “predatory” Spanish fiscal approach toward those who relocate their tax residence. Other creators, including streamer El Xokas, have publicly reported major inspections; El Xokas has said his case was ultimately resolved in his favour.

Both Willyrex and Vegetta777 remain prominent online. Their legal teams cite roughly 17.2 million subscribers for Willyrex and about 34.5 million for Vegetta777. The National Court will now consider the appeal against the TEAC rulings, a decision that could influence future disputes over tax residence for digital content creators.