We design Spanish holding companies, participation-exemption planning and IP ownership structures around real ownership, dividend, licensing and substance requirements — not around a headline rate.
A corporate structure has to explain how control, value and cash actually move — not just look tidy on a chart.
The right model starts with the business objective, not the headline rate. Each route needs its own legal, tax and operational evidence.
Dividends and capital gains from qualifying holdings may benefit from the Spanish participation exemption under Article 21 of the Corporate Income Tax Law (Ley 27/2014). The complete ownership and transaction profile must be reviewed before relying on the regime.
An assessment framework, not a statement of eligibility. The effective outcome depends on the facts in force at the time of the transaction.
A structure is tested flow by flow — where the money starts, where it lands, and what a reviewer will ask about each hop.
Tested against ownership, holding period, subsidiary status, beneficial ownership, EU rules and any relevant treaty. Main scrutiny: substance and anti-abuse.
Exit proceeds tested against the same participation-exemption chain. The holding period and qualifying-subsidiary profile decide the treatment.
Classification, DEMPE functions, arm's-length pricing and withholding. The IP owner must actually perform the functions the income implies.
A reduced-rate Canary Islands regime for genuine local operation — conditional on approved activity, investment, employment and real substance.
OECD BEPS, EU ATAD and Spanish anti-abuse rules put operational reality at the centre. A company described as the decision-maker, IP owner or operational centre needs the people, controls and records to support that description.
Private, remote 60-minute sessions with practical recommendations for founders, investors and international groups. Booked directly — secure checkout, no sales call to get to a sales call.
Spanish holding overview, participation exemption, cross-border tax considerations and comparison with alternative jurisdictions.
Optimal IP structure, registration strategy, ownership and licensing considerations, plus a practical risk review.
Sessions deliver practical direction; binding legal or tax opinions and implementation are scoped separately. Prefer to talk first? A free initial consultation helps decide which session fits — or whether a full structure review is the better route.
Beyond a single session, we connect corporate design with tax, reporting, banking and operational requirements before implementation — structural design, EU alignment, IP architecture, ZEC assessment and a risk review across DAC6, CFC, exit tax and anti-abuse exposure.
Tell us who owns the group, where the subsidiaries operate and how dividends, IP income or sale proceeds are expected to move.
Book a focused consultation ↗Voixa Consultors S.L. · Barcelona · General information on Spanish holding and IP structuring, not legal or tax advice. Participation-exemption, ZEC and treaty outcomes depend on the specific facts and require professional review. Consultation payments processed securely by Stripe.