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V2344-25 ·3 December 2025 ·consulta-vinculante Medium impact
Tax

A Swiss contractual fund may be deemed a rental attribution entity in Spain

The DGT confirms that a Swiss contractual fund, not taxing itself in Switzerland and attributing income to investors, constitutes a rental attribution entity and may benefit from the tax exemption under the double taxation treaty if it proves its status.

In 6 key points

Lifecycle

2025-12-03PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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