Tax

Tax Strategy: Planning & Structuring for Companies and Investors

International tax planning, transfer pricing, real estate taxation and tax due diligence. Efficient structures that protect your assets and optimise your tax position.

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Offices in Spain In practice since 2010 REAF · ICAM EN · ES · FR · DE native
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We accept a limited number of mandates each quarter. Inquiries are prioritised by urgency and fit with our current pipeline.

€800M+
Tax savings generated
90+
Jurisdictions covered
25+
Years of experience
100%
Regulatory compliance
Our services

Practice areas

BMC’s tax strategy practice designs tax structures that optimise the fiscal burden of businesses and groups in a legal, sustainable, and defensible manner. From corporate income tax planning to the structuring of international operations, our approach is always preventive: we anticipate AEAT review criteria before the transaction is executed.

Tax Planning and Corporate Income Tax Optimisation

Effective tax planning requires an in-depth understanding of available incentives and each company’s specific tax position:

  • Tax Planning: Comprehensive tax position analysis; IS optimisation via R&D deductions, accelerated depreciation, and tax consolidation; tax loss carryforward management.
  • International Tax: Cross-border transaction structuring; treaty application; permanent establishment analysis; dividends and royalties planning across jurisdictions.
  • Transfer Pricing: Master File and Local File documentation; comparability analysis; CbCR; advance pricing agreements (APAs) with AEAT.

Restructurings and Corporate Tax Transactions

  • FEAC Tax-Neutral Restructuring: Mergers, spin-offs, branch contributions, and share exchanges with full tax neutrality under Chapter VII, Title VII LIS. Valid business purpose analysis and binding rulings.
  • Tax Due Diligence: Pre-transaction tax review in M&A and LBOs; tax contingency identification; vendor due diligence; post-acquisition tax risk mapping.

Real Estate Tax

  • Real Estate Tax: Tax structuring of real estate investments in Spain; SOCIMI regime; non-resident withholding on property transfers; ITP/AJD; municipal capital gains; lease and rental income taxation.

Go deeper with our most recent analysis:

Equipo responsable
AGAna Garcia· Partner - Tax Division
Análisis y guías de referencia

Tax: nuestros análisis de referencia

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Whitepaper: Transfer Pricing — Guide for Multinationals

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Spain tax calendar 2026: all deadlines and obligations

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Spain Corporate Tax 2026: 25%, 23% and 15% Rates Explained

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BMC Insights

Reciba nuestros análisis de referencia

Casos, cambios normativos y oportunidades — directamente en su bandeja.

Términos clave en tax (5)
Transfer Pricing FEAC Tax Regime ETVE — Spanish Holding Company Regime (Entidades de Tenencia de Valores Extranjeros) Double Tax Treaty (Convenio de Doble Imposición) Holding Company in Spain
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Methodology

Our approach

Tax audit

Comprehensive review of current tax position and opportunity identification.

Structure design

Optimal tax structure aligned with business objectives.

Implementation

Strategy execution with documentation and ongoing support.

Monitoring

Regulatory tracking and adaptation to legislative changes.

Why choose us?

What sets us apart

360° vision

Comprehensive approach covering national, international and personal tax dimensions.

Tax due diligence

Exhaustive review of tax risks in corporate transactions.

FEAC experts

Tax-neutral restructurings applying the FEAC regime.

Nuestro equipo

Los profesionales que lideran esta área

Manuel Jimenez

Founder & Managing Director

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+34 910 917 811
FAQ

Frequently asked questions

Tax planning is the legitimate use of incentives, deductions, and special regimes established by law (economy of option under Art. 15 LGT). Tax evasion involves concealing taxable events or submitting false data, which constitutes a serious tax infringement or criminal tax fraud (Art. 305 Spanish Criminal Code). BMC works exclusively within the space of legitimate planning, always requiring a valid business purpose for any structure we design.
Under Art. 18 LIS and Royal Decree 634/2015, any entity conducting related-party transactions exceeding €250,000 with the same party is required to maintain specific documentation. Multinational groups with consolidated turnover above €750m must file the Country-by-Country Report (Form 231). AEAT prioritises review of transactions between Spain and low-tax jurisdictions.
The mergers, spin-offs, branch contributions, and share exchange regime (Arts. 76–89 LIS) allows these transactions to take place without triggering immediate taxation — deferring it to a subsequent disposal. It applies when there is a valid business purpose, a criterion AEAT scrutinises closely. Without a prior binding ruling or a solid legal-tax analysis, the transaction may be recharacterised with capital gains assessment and interest charges.
A Spanish Foreign Securities Holding Entity (ETVE) exempts dividends and capital gains from foreign subsidiaries from Spanish corporate income tax (Art. 21 LIS), subject to minimum participation and subsidiary-level taxation requirements. It is a particularly efficient holding structure for multinational groups with investments in Latin America, where Spain has an extensive treaty network.
No. Vendor tax due diligence — prepared by the seller before the process begins — identifies and addresses contingencies before the buyer discovers them and discounts them from the price. It reduces uncertainty for both parties, accelerates closing, and protects the seller from post-closing claims for tax contingencies unknown to the buyer.

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