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Optimise your international tax position with confidence

Specialist international tax advisory for companies with cross-border operations. Optimise your global tax burden with full legal certainty.

The problem

Cross-border operations multiply your company's tax complexity. Double taxation on the same profits, the risk of creating inadvertent permanent establishments, CFC rules that accelerate taxation on foreign subsidiaries, reporting obligations in multiple jurisdictions, transfer pricing challenged by the tax authorities... A poorly designed international structure not only increases the tax bill, but can trigger simultaneous tax liabilities in several countries, with compounding penalties.

Our solution

At BM Consulting we design international tax structures that optimise your group's global taxation while scrupulously complying with the rules of every jurisdiction involved. We combine deep knowledge of Spanish tax law with a well-established network of correspondents in over 15 countries to deliver coordinated solutions. Our team supports you from the initial diagnostic through to ongoing compliance, acting as a single point of contact for all your international tax needs.

Process

How we do it

1

Tax diagnostic

We analyse your group's current structure, cross-border income flows, applicable treaties, and existing obligations to identify risks, inefficiencies, and optimisation opportunities.

2

International planning

We design the optimal structure for your operations: investment vehicle, corporate entities, dividend, interest, and royalty flows, treaty utilisation, and anti-avoidance compliance.

3

Structural implementation

We execute the necessary changes: entity formation or restructuring, intercompany agreements, transfer pricing documentation, and group tax policy configuration.

4

Ongoing compliance

We manage recurring international reporting — CbCR, DAC6, CRS, related-party disclosures — and keep you informed of regulatory changes that affect your structure.

850M+
Managed internationally
28%
Average tax saving
15+
Jurisdictions covered

We had expanded internationally without coordinated tax planning and were overtaxed in three jurisdictions. BM Consulting reorganised the group's structure and achieved a sustainable tax saving of 31% without taking on any additional risk.

Javier Ortega Managing Director, Grupo Navantis SL

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The international tax challenge

The globalisation of business has made international tax one of the most critical and complex areas of corporate management. Regulatory frameworks from the OECD (BEPS), the European Union (ATAD I and II, DAC6), and national legislatures are evolving at pace, introducing new transparency obligations and restricting aggressive optimisation strategies.

In this context, companies with cross-border operations need proactive, up-to-date advisory that not only ensures compliance but identifies opportunities for tax efficiency within the new regulatory landscape.

Spain’s double tax treaty network

Spain has one of the most extensive double tax treaty networks in the world. These bilateral agreements are an essential tool for any business with international activity, as they allow you to:

  • Reduce or eliminate withholding taxes on dividends, interest, and royalties
  • Determine which country has taxing rights over specific business income
  • Avoid double taxation through exemptions or tax credits
  • Resolve disputes between tax authorities through mutual agreement procedures

Effective use of DTTs requires a detailed analysis of each transaction and deep knowledge of both the applicable treaty and the domestic legislation of each country involved.

Common scenarios we advise on

Our team has proven experience in tax planning for the most frequent international scenarios: expansion into new markets via subsidiaries or branches, international group restructurings, tax-efficient repatriation of profits, relocation of functions and assets, cross-border M&A transactions, expatriate management, and special regimes for posted workers.

Each scenario has its own tax implications, and the difference between proper planning and an improvised structure can represent a saving — or a cost — of hundreds of thousands of euros.

FAQ

Frequently asked questions

What is double taxation and how does it affect me?
Double taxation occurs when the same income is taxed in two countries: in the country where it is generated (source taxation) and in the country of residence of the recipient. Without planning, you could end up paying tax twice on the same profits, significantly eroding the profitability of your international operations.
How can double taxation be avoided?
Spain has signed over 90 double tax treaties (DTTs) that provide mechanisms to eliminate or reduce double taxation: exemptions, credits for taxes paid abroad, and reduced withholding rates. The key is to structure operations to make the most of these instruments.
Which double tax treaties does Spain have?
Spain has one of the most extensive DTT networks in the world, with treaties in force with over 90 countries, including all EU member states, the United States, the United Kingdom, China, Japan, Latin America, and most African nations. A DTT can reduce withholding rates on dividends, interest, and royalties from 19-24% to 0-10%.
What is a permanent establishment and why should I be concerned?
A permanent establishment (PE) is a fixed place of business in another country — an office, a warehouse, a construction site, or even an employee with contracting authority — that triggers full tax obligations in that territory. An unintended PE can mean unfiled returns, unpaid taxes, and retroactive penalties.
What obligations does a company with international operations have?
Depending on the structure and turnover, the main obligations include: related-party transaction disclosures, transfer pricing documentation (master file and local file), Country-by-Country Reporting for groups with turnover above 750M, DAC6 disclosures for certain cross-border arrangements, and CRS compliance for the automatic exchange of financial information.
What are CFC rules and how do they affect me?
Controlled Foreign Company (CFC) rules allow the Spanish tax authorities to tax in Spain the income of your subsidiaries in low-tax jurisdictions, even if no dividends have been distributed. If your group has entities in jurisdictions with effective tax rates below 15%, these rules can accelerate taxation in Spain and nullify the tax deferral you were seeking.

Take the first step

Request a no-obligation consultation and discover what we can do for your business.

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