Articles on international taxation, expatriates and business advisory.
How to pull profits out of a Spanish subsidiary up to a foreign parent: dividends, interest, royalties, management fees, capital reductions. Country-by-country WHT, ETVE, EU parent-subsidiary, substance, and Pillar 2.
How to correctly apply a Double Tax Treaty in Spain: residence certificates, Modelos 210/216/296, MLI PPT clause, US/UK/FR/DE/PT/LatAm case-by-case rates and the recurring errors AEAT regularises.
2026 guide to identifying when a foreign company's activity creates a permanent establishment in Spain: LIRNR criteria, OECD MTC, AEAT case law, typical scenarios and mitigation.
2026 tax comparison of Spain (ETVE), Portugal, Ireland and the Netherlands as jurisdictions for European holdings and subsidiaries: effective rates, exemptions, substance, Pillar 2.
Real cost breakdown of operating a Spanish subsidiary of an international group in 2026: incorporation, effective taxation, payroll, compliance, advisory. Indicative figures by company size.
2026 guide for foreign companies with remote employees in Spain: digital nomad visa, Beckham regime, A1 certificate, permanent establishment risk and EOR vs subsidiary.
2026 guide to opening a Spanish corporate bank account as a foreign-owned company: UBO requirements, NIF, banks vs neobanks, typical timelines and common pitfalls.
2026 guide for Spanish subsidiaries of international groups: audit procedure, deadlines, taxpayer rights, AEAT focus areas and defense strategies.
Complete 2026 guide to Spanish withholding tax (IRNR) for international groups: 24%/19% rates, DTT reductions, Modelo 216 and 296 deadlines, Parent-Subsidiary exemption.
Managing a subsidiary in Spain under the “Big Four” model usually prioritizes mass compliance but often ignores a critical factor: the director’s personal vulnerability. In the Spanish legal ecosystem, executive liability is extensive and direct, operating under a regime where operational negligence or non-orderly cessation of activity can pierce the shield of the Limited Liability Company.
