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Expand internationally with full tax certainty

Tax advisory for cross-border operations, international expansion, and multi-jurisdictional compliance.

The challenge

International expansion multiplies tax complexity: double taxation, permanent establishments, reporting obligations across multiple jurisdictions, CFC rules, and anti-avoidance regulations. A poorly designed structure can generate excessive taxation or, worse still, tax contingencies in several countries simultaneously.

Our solution

We design international tax structures that optimise your group's global tax position while complying with the regulations of every jurisdiction involved. We combine deep Spanish tax expertise with an international partner network to deliver comprehensive, coordinated solutions.

Process

How we work

1

Market & transaction analysis

We study the tax implications of your international expansion: investment structure, legal form, destination country taxation, and applicable treaties.

2

Structure design

We propose the corporate and financial flow structure that minimises the global tax burden, avoids double taxation, and complies with anti-avoidance rules.

3

Treaty optimisation

We leverage double taxation treaties, EU directives, and multilateral agreements to reduce withholding tax on dividends, interest, royalties, and capital gains.

4

Compliance & reporting

We implement tax compliance procedures across all jurisdictions and coordinate international reporting: CbCR, DAC6, CRS, and local obligations.

International taxation requires an integrated perspective that combines knowledge of Spanish law with that of destination countries. Our team works in close coordination with local advisers across key jurisdictions to ensure that every structure is robust, efficient, and defensible before any tax authority.

FAQ

Frequently asked questions

What are double taxation treaties and how do they benefit me?
They are agreements between countries to prevent the same income from being taxed twice. Spain has signed over 90 treaties. Proper use of these treaties can significantly reduce withholding tax on dividends, interest, and royalties paid abroad.
What is a permanent establishment and why should I be concerned?
It is a fixed place of business in another country that creates tax obligations in that territory. An office, a warehouse, or even a single employee can constitute a permanent establishment. Its inadvertent creation can generate unexpected tax liabilities and penalties.
What are CFC rules?
Controlled Foreign Company (CFC) rules allow Spain to tax income of subsidiaries in low-tax jurisdictions even if it has not been distributed as dividends. Any international structure must account for these rules to avoid unplanned early taxation.
What is BEPS and how does it affect my business?
BEPS (Base Erosion and Profit Shifting) is the OECD framework combating tax base erosion. It has given rise to new obligations such as Country-by-Country Reporting, economic substance requirements, and interest deductibility limitations that affect every international group.
How do EU directives affect my group?
Directives such as the Parent-Subsidiary Directive, Interest and Royalties Directive, and ATAD I and II establish both benefits (exemptions) and obligations (anti-avoidance rules) for groups with an EU presence. Proper application is key to international tax planning.
What happens with a transfer of tax residence abroad?
The transfer of residence of an individual or entity carries significant tax consequences, including exit tax (taxation of unrealised capital gains). It is essential to plan any transfer well in advance to minimise the tax impact.
Do I need local advisers in each country?
For local compliance matters, yes. We coordinate the relationship with local advisers in each jurisdiction, acting as a single point of contact so you do not have to manage multiple counterparts.

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