Assume a limited company registered in Hong Kong.
The director of the company is an Spanish national who does not live in Hong Kong and does not have the status of resident in Hong Kong. Also, is rarely physically in Hong Kong. He does not stay long enough in any country as to receive the status of resident in that country. It means he is hopping through multiple countries but never gets a residence permit and never gets tax liable in any of those countries. Also, is very rarely in Spain and specifically does not work in Spain.
Now, the company gives the director a salary as director of the company. As per Hong Kong regulations, this salary is subject to income/personal tax in Hong Kong, no matter where the director is resident. So the director must pay income tax, at least in Hong Kong.
Question here is, In addition to Hong Kong, would the director be tax liable in Spain?
There is an agreement between both countries which is available here: http://www.hacienda.gob.es/Documentacion/Publico/NormativaDoctrina/Tributaria/CDI/BOEIN_Hong-Kong.pdf I was going through it, but I cannot really figure out the answer to that question because the text uses many legal terms and I am not familiar with it.