In accordance with the Double Taxation Treaty between Spain and Germany, although a company’s own jurisprudence says something different, it can only be tax-resident in one country, and this is where its effective registered office is located.
As to the Spanish point of view, the effective registered office is in Spain, whenever the company’s Administrators are tax-resident in Spain.
Since this is sometimes difficult to be determined, we remain at your entire disposal for giving advice to all those clients who find themselves in such a situation.