The taxation of a family holding company is a key issue for family businesses seeking to optimise the taxation of dividends and capital gains, protect their assets and plan for generational succession. For many years, holding structures were traditionally associated with large corporate groups. However, their use has increasingly expanded into the family business sphere. […]
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Unjustified Capital Gains constitute one of the most common grounds for adjustment in Personal Income Tax (IRPF) where the Tax Authorities identify undeclared assets or rights in the course of a review or inspection procedure. Throughout this post, we shall examine the most recent judgments of 27 November 2025 delivered by the Supreme Court (appeals […]
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A Foreign Securities Holding Company (hereinafter, ETVE by its Spanish acronym) is a Spanish company whose principal purpose is the management and administration of shareholdings in non-resident entities. The main appeal of these entities lies in their favourable tax treatment, since, provided certain requirements are met, dividends and capital gains derived from their foreign subsidiaries […]
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Legal framework of corporate tax rates Law 27/2014 of 27 November on Corporate Income Tax (LIS) has introduced a major reform of corporate taxation in Spain. One of the central elements of this reform is found in Article 29, which regulates the tax rates applicable to taxpayers. In addition, Transitional Provision 44 establishes a temporary […]
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One of the tools available to companies for optimising their tax burden is the use of tax loss carryforwards. However, this mechanism cannot always be applied. Article 26.4 of Law 27/2014 of 27 November on Corporation Tax (hereinafter, the “CIT Law”) sets out a series of restrictions that prevent the utilisation of tax loss carryforwards […]
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On 21 December 2022, Law 28/2022 of 21 December, on the promotion of the ecosystem for emerging companies (hereinafter, the startup law), was published. In Spain, an emerging ecosystem of startups has been developing, and with the aim of reinforcing and promoting such companies as one of the driving forces behind the recovery and modernisation […]
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Undoubtedly, the VAT taxation of services provided by individual Chief Executive Officers to commercial companies is one of the most controversial issues faced by companies and entrepreneurs on a daily basis, and as such, it generates significant interest.
For years, the uncertainty about the correct way to issue an invoice […]
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In previous posts in our blog, we have highlighted the growing interest in Free Investment Companies (SIL), as they are flexible investment vehicles that allow investment in any type of financial asset (shares, stocks, crypto-assets, etc.), offering a minimum taxation in the Corporate Income Tax. In today’s post, we will detail the main tax benefits […]
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In the context of a globalised economic system in which commercial relations between companies from different countries are a fact of life, the question arises as to how this will affect their taxation. Specifically, if a company incorporated in Spain supplies goods or services to companies not established in Spain for which it obtains income […]
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There are many cases in which a company established in Spain distributes dividends to its partner who is not a tax resident in Spain. In this type of case, both Spanish companies and non-resident partners encounter difficulties in determining the taxation of this income. This is due to the fact that not only are Spanish […]
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One of the most controversial aspects of the Value Added Tax (VAT) Law is the deductibility of input VAT. Companies often encounter difficulties in determining the correct way to deduct input VAT when they simultaneously carry out transactions that give rise to a right to deduct, i.e. transactions that are subject to and not exempt […]
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