The 20% rule for Spanish clients on the DNV: how to calculate it

What the law says about 20% Spanish clients

Article 74 bis.1 of Ley 14/2013: in the case of professional activity (actividad profesional), the holder of a teletrabajo permit may work for an “empresa ubicada en España” as long as that work makes up no more than 20% of their total professional activity. The wording “no sea superior al 20 %” means that exactly 20% is allowed [1]. An employee (actividad laboral) may, under the law, only work for companies outside Spain [1].

The UGE repeats this in its guidance: work for a Spanish company is possible if the professional link with the foreign company on which the application is based is maintained, it is specifically a relación profesional (nunca laboral, never an employment relationship) and the share does not exceed 20% [2]. The consulate in Moscow says the same [4].

How the share is calculated: what the official texts leave out

Neither the law, nor the UGE FAQ, nor the reference document on required documents answers three questions. What to measure the share against: revenue, working hours, number of orders or clients. Over what period: a year, the three months before applying, the whole term of the permit. As of what date to check it. We have not found an official method [1][2][3].

What is known is this. The UGE may request additional documents at any time [3], and on renewal the Dirección General de Migraciones may request reports on whether the conditions still apply [1]. Our cautious approach is not an official requirement: look at the strictest of the reasonable options. Measure the share by revenue (invoice amounts) and by working time, use a rolling twelve months and keep a margin. If Spanish clients stay within 20% on both measures, there is less room to object to the method.

Formula and example: 20% of the total, not of the foreign share

Spain’s share = Spanish revenue divided by total professional revenue (Spanish plus foreign). A typical mistake: dividing Spanish revenue by foreign revenue. The amounts in the table are illustrative and have nothing to do with the DNV income thresholds.

With foreign revenue of €80,000, Spanish revenue can reach €20,000, i.e. 25% of the foreign part. So the formula “20% of foreign revenue” understates the permitted volume (in the example, €16,000 instead of €20,000): calculate from the whole. If a large Spanish order comes in during the year, it changes the share for the whole year, not just the months in which it is paid.

A single Spanish client, intermediaries and borderline cases

• One large Spanish client is acceptable if it stays within 20%: the rule counts the share, not the number of clients [1].
• A client who is a private individual. The article refers to an “empresa ubicada en España” (a company located in Spain). A private client is not named explicitly; it is safer to count them as a Spanish client.
• A foreign company with a Spanish branch. For employees, the UGE explains that if the company has a branch in Spain, this is an intra-corporate transfer (ICT), not teletrabajo [2]. For a freelancer whose foreign client has a Spanish subsidiary, the sources give no answer.
• A foreign agency or platform with the end client in Spain. The contract and invoice are with a foreign company, but the work is for a Spanish customer. Who counts as the client is not defined; check before applying.
• Income threshold. Proof of income is based on professional relationships with foreign companies and invoices for three months [3]. We do not include Spanish revenue when calculating the threshold. More: how to calculate income.

What happens if you exceed 20% after approval

The law requires you to keep the conditions on which the permit was granted (additional provision 7 of Ley 14/2013). Changes affecting those conditions must be reported to the UGE within 30 days. Public authorities may check compliance, and in the event of a breach the authority may terminate the permit by a reasoned decision after a trámite de audiencia (a hearing of the person concerned) [1]. We have not found any statistics on how these rules are applied to the share of Spanish clients.

The practical conclusion: it is better to fix an excess in advance than to explain it at renewal, which is granted for two years and requires the conditions to still apply [1]. If the share has already gone over 20%, discuss the situation with a lawyer before contacting the UGE: how it is classified depends on the circumstances. How renewal works: renewal after three years.

How to keep records to prove the share

The 20% rule only applies to the authorisation holder

The restriction applies to the teletrabajador themselves. According to the UGE’s guidance (FAQ, question 17), family members who have been granted a permit may work without restrictions, both as employees and self-employed [2]. This means a spouse may have a Spanish employer. How this works in practice and how it affects the application should be checked separately. Family cases: Digital Nomad family.

Common mistakes

• Reading “20%” as “at least 20%” or as “20% of foreign revenue”.
• Calculating only by revenue and ignoring hours, or the other way round.
• Leaving a one-off Spanish order out of the annual share.
• Signing an employment contract with a Spanish client. The UGE only allows professional relationships [2].
• Not keeping a register of invoices: if documents are requested, you will have to reconstruct the picture from bank statements.
• An employee looking for a “20% limit”. For an employee, a Spanish employer is not allowed at all [1].

A comparison with another ground for freelancers: DNV or autónomo. Contracts and Spanish clients: Digital Nomad for freelancers.

When you need an individual review

A review before applying is needed if Spanish orders already make up 15 to 20%, if you expect a large Spanish contract after getting the permit, if you work through an agency or platform with the end client in Spain, or if your foreign client has a Spanish subsidiary. In all these cases the answer depends on the contracts and on exactly how the payments are structured, and there is no official calculation method.

How we can help

The ReloVictory team in Barcelona reviews your client structure, calculates the share of Spanish work by revenue and by hours, checks the contracts and prepares the documents for the UGE. The legal side is handled by the team’s lawyer, the tax side by a graduada social. First consultation: 15 minutes free; full consultation: €121 for 45 minutes. Booking: consultation. Service page: digital nomad residence permit.

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ReloVictory · Sources reviewed 02.10.2026 · Not a substitute for individual legal advice.