Tax advisor in Madrid — enterprise-grade fiscal planning at the centre of Spain's corporate economy
Corporate tax advisory in Madrid for multinationals, HQ relocations and large groups. Transfer pricing, AEAT inspections, IS planning, and international structuring from Spain's fiscal capital.
Request a Madrid corporate tax consultation- REAF
- ICAM
- 5 Offices in Spain
- 25+ Years
- 30+ Jurisdictions
The problem
Madrid is where Spain's corporate tax decisions are made and, increasingly, where they are contested. The AEAT's central inspection bodies — the Delegacion Central de Grandes Contribuyentes and the Unidad de Gestion de Grandes Empresas — are headquartered in Madrid. IBEX 35 groups, major foreign subsidiaries, and the Spanish holding entities of global multinationals are managed from the capital. The concentration of corporate fiscal activity here is unmatched anywhere else in Spain, and the tax issues that arise are correspondingly complex. For a multinational group establishing or expanding its Spanish operations from Madrid, the fiscal questions are substantial: the optimal legal structure for a Spanish HQ entity, the transfer pricing framework to document and defend intercompany transactions, the application of the Participation Exemption to dividends and capital gains within the group, the permanent establishment risk of centralising functions in Spain, the design of financing structures that comply with Spain's thin capitalisation and interest limitation rules, and the interaction of Spanish corporate tax with applicable double tax treaties. These are not issues that generalist advisors handle well. Madrid requires a tax practice with direct AEAT inspection experience, deep transfer pricing capability, and the corporate tax technical depth to plan and defend complex group structures.
Our solution
BMC's Madrid office is the firm's national headquarters and corporate tax centre. Our tax team in Madrid advises large and mid-market Spanish companies, multinational groups with Spanish subsidiaries, and international businesses relocating their European or Iberian HQ to the capital. We handle the full corporate tax lifecycle: annual Impuesto sobre Sociedades planning and compliance, transfer pricing documentation and defence, AEAT inspection management and administrative appeals, M&A tax structuring, HQ relocation advisory, and the tax treatment of group financing and treasury structures. Madrid is also BMC's centre for international tax mandates: inbound investment structuring, treaty application, permanent establishment analysis, and the tax implications of cross-border M&A and corporate reorganisations. Our clients include Spanish operating groups, foreign-owned subsidiaries, and international investors deploying capital into Spain through Madrid entities. All engagements are handled by senior tax lawyers and economists with direct AEAT and TEAC experience.
How we do it
Corporate tax diagnostic and IS planning
We review your current Impuesto sobre Sociedades position — the effective tax rate, available credits and deductions, loss carryforward position, and the tax treatment of intragroup transactions — and design the optimal annual IS planning strategy. For groups, we model the consolidated tax position and identify legitimate reduction opportunities within the Regime Especial de Consolidacion Fiscal, capitalisation reserves, and the Research, Development and Innovation (R+D+I) deduction framework.
Transfer pricing documentation and benchmarking
We prepare and maintain the full transfer pricing documentation required under Spanish law (Article 18 LIS and Royal Decree 634/2015): master file, local file, and country-by-country reporting where applicable. We conduct economic benchmarking studies, apply the appropriate OECD transfer pricing methods, and document the arm's length nature of intercompany transactions. For groups already under AEAT scrutiny, we prepare the technical defence file and manage all AEAT communications.
AEAT inspection management and administrative appeals
When the AEAT opens a corporate tax inspection — whether a full scope Actuacion General or a limited Actuacion Parcial — BMC manages the entire process from the initial notification to final resolution. We represent the taxpayer before the Equipo Regional or the Unidad de Gestion de Grandes Empresas, negotiate the scope of information requirements, prepare technical responses, and if necessary, pursue administrative appeal before the TEAC and judicial review before the Audiencia Nacional.
M&A and corporate reorganisation tax structuring
We advise on the tax structuring of acquisitions, disposals, mergers, spin-offs, and corporate reorganisations involving Spanish entities. This includes the application of the Regime Especial de Fusiones y Escisiones (tax neutrality for qualifying reorganisations), the structuring of acquisition financing to optimise deductibility within Spain's interest limitation rules, the design of the exit structure to maximise Participation Exemption eligibility, and the management of the AEAT notification obligations for qualifying reorganisations.
We relocated our Iberian HQ to Madrid from Lisbon and needed a tax team that understood both the structural planning and the AEAT relationship. BMC handled the HQ migration, set up the transfer pricing framework for our 12-entity Spanish sub-group, and managed our first AEAT inspection without a single additional tax assessment. The quality of technical advice and the directness of communication were exactly what we needed from a Madrid advisor.
Madrid: Spain’s corporate tax capital
Spain’s corporate fiscal machinery is centred in Madrid. The Agencia Estatal de Administracion Tributaria (AEAT) has its national headquarters in Calle Infanta Mercedes. The Delegacion Central de Grandes Contribuyentes — Spain’s large taxpayer unit, responsible for inspecting groups above EUR 100 million in revenue — operates from the capital. The Tribunal Economico-Administrativo Central (TEAC), the first mandatory stage of administrative appeal against AEAT decisions, sits in Madrid. When corporate tax disputes in Spain reach judicial review, they go before the Audiencia Nacional and ultimately the Tribunal Supremo, both in Madrid.
For a group with material Spanish operations, being advised by a Madrid tax team with direct AEAT inspection and TEAC appeal experience is not a convenience — it is a structural advantage. BMC’s Madrid office, located in the Barrio de Salamanca at C/ Castello 36, Planta 1, is the firm’s national corporate tax centre and the team that manages the most complex group mandates.
Services for multinational groups operating from Madrid
The tax advisory needs of a multinational operating from Madrid span the full corporate tax lifecycle. At the planning stage: the optimal Spanish holding structure, the application of the Participation Exemption and the ETVE regime, the design of intercompany financing within Spain’s interest limitation rules, and the transfer pricing framework that governs transactions between the Spanish entities and the wider group. At the compliance stage: Impuesto sobre Sociedades preparation and filing, transfer pricing documentation (local file, master file, CbCR), related-party transaction reporting under modelo 232, and IS instalment payments. At the controversy stage: AEAT inspection management, technical defence preparation, administrative appeal before the TEAC, and judicial review before the Audiencia Nacional.
BMC handles all three stages. Our Madrid tax team includes corporate tax lawyers, economists qualified to issue binding transfer pricing reports, and former AEAT officials with direct inspection experience. For large group clients, we provide a dedicated senior partner as single point of contact across all tax matters, including coordination with the group’s home-country advisors on cross-border positions.
AEAT inspections and tax litigation in Madrid
An AEAT inspection of a large Madrid company is a sustained, technically demanding process. The Unidad de Gestion de Grandes Empresas or the Delegacion Central assigns experienced inspectors who focus on high-value issues: transfer pricing, the Participation Exemption, the reality of IS deductions, the substance behind holding and royalty structures, and the tax treatment of complex financial instruments. The process can run for years, and the technical and procedural decisions made in the first months — what information to provide, how to characterise contested positions, whether to regularise voluntarily — have decisive consequences for the final outcome.
BMC brings three capabilities that matter in this context. First, technical depth: our Madrid tax team produces the transfer pricing studies, economic analyses, and legal memoranda that defend contested positions with the rigour the AEAT and TEAC demand. Second, procedural experience: we understand the AEAT’s internal procedures, the mandatory timelines, the rights of the taxpayer during inspection, and the mechanics of the administrative appeal system. Third, strategic judgment: we advise clients when to regularise a position early, when to contest, and how to sequence a multi-issue dispute across the administrative and judicial stages to maximise the overall outcome.
For groups that have received an AEAT notification and need immediate specialist support, BMC Madrid is available for urgent engagement regardless of whether a prior advisory relationship exists.
International tax planning from Madrid
Madrid’s position as Spain’s gateway for international capital makes it the natural base for inbound investment structuring and outbound group reorganisations. Spain’s treaty network of over 100 double taxation agreements, combined with the ETVE regime and the Participation Exemption, creates a competitive platform for holding structures, regional headquarters, and intra-European royalty and finance flows when correctly structured with appropriate substance.
BMC advises international clients on the full inbound investment cycle: pre-entry analysis of the Spanish tax landscape, design of the acquisition or greenfield structure (direct versus corporate vehicle, debt-equity mix, intercompany financing terms), establishment of the Madrid entity with the substance required to access treaty benefits and the Participation Exemption, and ongoing IS planning to manage the effective tax rate of the Spanish operations.
For groups considering Madrid as a European HQ location — attracted by the combination of the ETVE regime, Spain’s treaty network, competitive talent costs, and the time zone advantage for managing both Americas and European operations — BMC provides a comprehensive HQ migration advisory, from the structural mapping and exit tax analysis in the current HQ jurisdiction to the full setup of the Madrid entity and its tax compliance infrastructure.
Our Madrid office is reachable at madrid@bm.consulting and +34 910 917 811. Initial consultations are available in English, Spanish, German, and French.
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