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MEDIUM
FISCAL

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

V2344-25

Prepared and reviewed by the BMC editorial team  ·  Methodology

Technical details

Type
consulta-vinculante (what is this?)
Identifier
V2344-25
Published
3 Dec 2025

Summary

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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