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Tax advisor in Marbella — sophisticated tax planning for international residents

High-net-worth tax advice in Marbella for expats, non-doms and international investors. IRPF, wealth tax, Beckham Law, trust structures and estate planning.

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The problem

Marbella attracts a different calibre of international resident and investor than almost anywhere else in Spain. The Golden Mile, Puerto Banús, Sierra Blanca, and La Zagaleta are home to high-net-worth individuals from the UK, Germany, Scandinavia, the Middle East, and Latin America whose financial affairs are anything but straightforward. Complex income structures — trust distributions, offshore company dividends, carried interest from private equity funds, rental income portfolios spanning multiple countries — sit alongside significant Spanish property holdings that create their own tax obligations. The intersection of Spanish tax law, applicable double tax treaties, and the domestic rules of clients' home jurisdictions is precisely where errors occur. A wealthy British national living on the Golden Mile who does not understand how their UK trust distributions are treated under Spanish resident tax law can face unexpected IRPF bills and penalties. A German entrepreneur who relocates to Marbella without coordinating their German exit taxation with their Spanish entry structure can crystallise unnecessary German tax. A Scandinavian investor who owns three Marbella properties through a foreign holding company may be unknowingly subject to Spain's anti-avoidance rules on deemed income.

Our solution

BMC's tax practice in Marbella is built around complex, high-value international tax mandates. We have deep experience advising on the full Spanish tax exposure of high-net-worth individuals — IRPF, Patrimonio, and the Impuesto Solidario de las Grandes Fortunas — while coordinating with advisors in clients' home jurisdictions to manage the bilateral picture. Our team advises on the Beckham Law regime, on the tax treatment of trusts and foreign entities under Spanish law, and on legitimate planning structures that reduce Spanish tax exposure without triggering anti-avoidance provisions. We work discreetly and at the standard expected by internationally mobile high-net-worth clients. Everything is handled in English (and where needed, German or other languages), with clear written advice and no surprises.

Process

How we do it

1

Comprehensive tax exposure mapping

We map your full Spanish tax exposure across IRPF (worldwide income), Patrimonio (worldwide net assets for residents, Spanish assets for non-residents), and the Impuesto Solidario. We identify all filing obligations — resident and non-resident — and flag any historic compliance gaps that should be addressed proactively.

2

Arrival and residency structuring

If you are planning to relocate to Marbella, we structure your arrival to minimise the tax triggered in both your home country and Spain. We assess Beckham Law eligibility, advise on the treatment of existing assets and income streams under Spanish law, and coordinate with home-country advisors to manage the exit and entry tax positions simultaneously.

3

International structures and anti-avoidance

We advise on the Spanish tax treatment of trusts, offshore companies, and other foreign entities in which you have interests. Spanish anti-avoidance rules (CFC legislation, transparency rules for low-tax jurisdictions, the GAAR) apply to many common structures used by internationally mobile HNW individuals — we ensure your arrangements are robust.

4

Annual compliance and strategic review

We manage your annual IRPF, Patrimonio, and Modelo 720 filings, coordinate with your investment advisors on the tax treatment of portfolio events, and conduct an annual strategic review to ensure your planning remains optimal as both your circumstances and Spanish tax law evolve.

90+
Countries covered by Spain's double tax treaty network
€700,000
Typical Patrimonio exemption threshold in Andalucía
24%
Beckham Law flat rate on Spanish-source income (up to €600k)

I moved from London to the Golden Mile with a complicated financial picture — a family trust, UK property, and significant investment portfolios. BMC mapped the full Spanish position, coordinated with my UK advisors, and structured everything correctly from day one. Three years in, my Spanish tax affairs are completely under control and I am paying what I should — not a euro more.

Jonathan Ashworth-Davies Private client, Former partner, financial services, London

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We respond within 4 business hours · 910 917 811

Marbella: Spain’s most international tax environment

No other location in Spain brings together such a concentration of internationally mobile wealth as Marbella and its surrounding municipalities. The Golden Mile, Puerto Banús, Sierra Blanca, Nueva Andalucía, and the ultra-private La Zagaleta estate are home to residents from dozens of countries, each carrying their own domestic tax history, foreign asset portfolios, and compliance obligations that must be mapped and managed under Spanish law.

This is not a market for generalist accountants. The tax issues that arise for Marbella residents — multi-jurisdictional investment portfolios, foreign trusts and foundations, offshore corporate structures, complex pension arrangements from multiple countries, carried interest and performance fee income from investment funds — require advisors who operate at the same level of sophistication as the clients themselves.

BMC’s Marbella tax practice is built for exactly this environment.

Spanish wealth tax: Marbella-specific considerations

Spain’s wealth tax (Impuesto sobre el Patrimonio) applies to worldwide net assets for Spanish residents and to Spanish assets for non-residents. Andalucía’s generous regional exemptions have historically made Marbella residency attractive for high-net-worth individuals concerned about wealth tax — but the introduction of the national Impuesto Solidario de las Grandes Fortunas in 2023 has changed the landscape for the very wealthiest clients.

Understanding exactly where you fall within this framework — resident or non-resident, which assets are in scope, how mortgages and other liabilities reduce the taxable base, and whether legitimate planning options exist within the anti-avoidance rules — requires a thorough annual review. BMC provides this as part of every HNW client engagement.

The relocation advisory service: structuring your arrival correctly

Relocating to Marbella is a tax event of the first order. In the year of arrival, decisions made or missed can cost hundreds of thousands of euros. The Beckham Law election expires six months after registering with Social Security. Capital gains on foreign assets that are crystallised before Spanish residency commences are taxed very differently from the same gains realised one day later. Foreign pension contributions made before arrival are treated differently from those made after.

BMC offers a dedicated relocation tax advisory service for individuals planning to move to Marbella, designed to ensure that everything — from the timing of your official move date to the structure of your worldwide portfolio on arrival — is optimised before you take up residence.

Confidentiality and discretion as standard

Marbella’s internationally wealthy community values discretion. BMC operates under the full confidentiality obligations of Spanish professional legal and advisory services, and understands that the detail of a client’s financial affairs is not for general discussion. All consultations are confidential, all advice is provided in writing, and client matters are handled by senior advisors with experience of the highest-value and most complex mandates.

FAQ

Frequently asked questions

Spanish tax law does not recognise the trust as a legal concept. For a Spanish tax resident who is a beneficiary of a foreign trust, distributions may be treated as income subject to IRPF, or the underlying trust assets may be attributed to the resident for Patrimonio purposes under Spain's transparency rules. The correct treatment depends on the type of trust, its terms, and whether distributions are discretionary or mandatory. BMC analyses each client's trust position individually and takes a defensible filing position supported by appropriate documentation.
The Impuesto Solidario de las Grandes Fortunas (solidarity wealth tax) was introduced in 2023 as a national tax applying to net assets above €3 million, at rates of 1.7% to 3.5%. Crucially, it overrides regional Patrimonio exemptions — including Andalucía's — meaning that residents of Marbella with very high net worth cannot entirely escape wealth tax through regional planning. The solidarity tax applies to worldwide assets for Spanish residents and to Spanish assets for non-residents. BMC advises on legitimate planning to manage this exposure.
The Beckham Law (régimen especial de trabajadores desplazados, reformed by the Ley de Startups 2023) taxes qualifying new residents at a flat 24% on Spanish-source income up to €600,000, rising to 47% above that threshold. It also excludes worldwide income from the base for up to five years. For high earners relocating to Marbella to take up employment or conduct business as a self-employed professional, it can represent a very significant saving versus the standard resident IRPF progressive scale. The application window is six months from Social Security registration — early planning is essential.
Yes. Non-residents who own Spanish property are subject to Patrimonio on the value of their Spanish assets, even if they pay no other Spanish tax. Andalucía provides a €700,000 deduction, but the net Spanish asset base (property value minus any Spanish mortgage) above that threshold is taxable at rates of 0.2% to 2.5%. For high-value properties on the Golden Mile or in La Zagaleta, this is a material obligation. BMC files non-resident Patrimonio returns and advises on structuring options.
Germany imposes exit taxation (Wegzugsbesteuerung) on individuals who have held shares in corporations above a 1% threshold when they cease German tax residency. This creates an immediate deemed disposal at market value. The interaction with Spain's entry rules — and the question of whether Spain grants a step-up in base — requires careful coordination between German and Spanish advisors before the move is made. Retroactive planning after arrival is significantly less effective and sometimes impossible.

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