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A consulting company wishes to establish an ETVE in Spain held by a Canadian 'Foreign Partnership'. The DGT determines that said entity is analogous to entities under the income attribution regime (ERAR) and that, to apply the ETVE regime, the characteristics of each partner must be considered rather than the entity itself.
Question raised 1) What should be the tax treatment in Spain of the income distributed by the ETVE to the Foreign Partnership entity, given the circumstances indicated in the consultation, specifically that at least two partners of the entity are managed by or are part of BID and another partner is managed by or is part of BEI.
The Canadian 'Foreign Partnership', lacking its own legal personality and attributing profits to its partners, has a legal nature identical or analogous to Spanish entities under the income attribution regime (ERAR). Therefore, for the application of the ETVE regime, the characteristics of each partner or participant of the transparent entity must be considered. In the case of US LLCs treated as 'disregarded entities', they are considered residents in the US in the same proportion as their partners are, allowing for the application of the Double Taxation Convention.
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