Areas of expertise
Specializations
- Tax optimization
- Special tax regimes
- Non-resident taxation
Languages
Biography
Role
Ana Garcia is part of the BMC team as Partner - Tax Division, based in the Madrid office.
Practice areas
- Tax planning
- International taxation
- Transfer pricing
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Services led
Practice areas where Ana serves as lead advisor or active contributor
Compliance with Spain's mandatory electronic invoicing obligation: analysis under the Ley Crea y Crece, implementation of Verifactu or SIF systems, integration with existing software and management of the phased entry-into-force timeline.
View service Crypto & Digital Asset TaxSpecialist tax advisory on cryptocurrencies, NFTs, DeFi, and other digital assets for individuals and businesses.
View service Beckham Law / ImpatriatesEnd-to-end management of Spain's special tax regime for inbound workers: eligibility, application, and optimisation.
View service US Business Owners Living in SpainEnd-to-end tax advisory for US founders and executives who reside or plan to reside in Spain: LLC, check-the-box, Beckham Law, Form 720, ITSGF, and US × Spain structure.
View service Non-Resident Tax (IRNR)Advisory and compliance for Spain's Non-Resident Income Tax for individuals and entities without Spanish tax residency.
View service Special TerritoriesExpert advisory on the tax regimes of the Canary Islands, Ceuta, and Melilla to maximise available incentives.
View service Corporate Income TaxPlanning and compliance for Spanish corporate income tax: base optimisation, deductions, instalment payments and audit defence.
View service Tax Advisory for Freelancers and Self-Employed in SpainComprehensive tax management for self-employed professionals in Spain: quarterly VAT and income tax returns, annual IRPF filing, deduction optimisation and ongoing advice on a fixed monthly fee.
View service Tax ComplianceComprehensive management of periodic tax obligations: return filing, tax calendar, compliance audits, and representation before the Spanish Tax Agency (AEAT).
View service Trade & CustomsSpecialist advisory on customs duties, Intrastat declarations, certificates of origin, and special customs regimes for companies trading internationally.
View service VAT AdvisoryComprehensive VAT advisory for businesses in Spain: pro-rata, SII, OSS/IOSS, input VAT recovery and periodic compliance.
View service International TaxTax advisory for cross-border operations, international expansion, and multi-jurisdictional compliance.
View service Real Estate Tax Advisory in SpainSpecialist real estate tax advisory: ITP transfer tax, AJD stamp duty, VAT on new developments, income tax on rental yields, and SOCIMI regime for investment portfolios.
View service Tax Due Diligence in Spain: CIT, VAT and AEAT Risk in M&ASpecialist tax due diligence for M&A transactions in Spain: Corporate Income Tax contingencies, VAT, transfer pricing, tax loss carry-forwards, AEAT exposure and SPA contractual mechanisms.
View service Tax Restructuring: FEAC Neutrality Regime in SpainAdvisory on Spain's FEAC tax neutrality regime (Arts. 76-89 LIS): mergers, full and partial demergers, business unit contributions and share swaps with full corporate tax deferral.
View service Tax PlanningLegal and efficient tax strategies to reduce your company's tax burden and protect your personal wealth.
View service Transfer PricingTransfer pricing policies and documentation that protect your group against audits and double taxation.
View service Inheritance & Gift Tax PlanningSpanish Inheritance and Gift Tax (ISD) planning: family business exemption, regional variations, donation structures and non-resident inheritance tax.
View service R&D Tax Incentives & Patent BoxR&D and technological innovation tax deductions (Art. 35 LIS), Patent Box regime and Binding Motivated Report for maximising Spain's innovation tax incentives.
View service Tax Litigation & DisputesDefence in AEAT inspections, appeals against tax assessments before TEAR/TEAC, contentious-administrative proceedings and Tribunal Supremo casation in Spain.
View service Voluntary Tax Disclosure in Spain (Art. 252 LGT)Advisory and representation in voluntary tax regularisation before criminal proceedings or AEAT investigation: criminal law exemption under Art. 252 LGT, late-filing surcharges without penalties, confidential handling.
View service Wealth Tax & High Net Worth PlanningPlanning for Spanish Wealth Tax (IP) and the Solidarity Tax on Large Fortunes (ITSGF): family business exemption, holding structures, Beckham Law interaction and exit tax.
View service AEAT Tax Audit Defence (Inspección Tributaria)Full AEAT tax audit defence: 18-month (27-month for complex cases, Art. 150 LGT) inspection procedure, acta de conformidad vs. acta de disconformidad strategy, voluntary regularisation, 78% success rate, €60M+ defended.
View service Corporate Holding StructuresCorporate holding company advisory in Spain: Art. 21 LIS 95% dividend and capital gains exemption, share exchange (Art. 80 LIS) under fiscal neutrality regime (Arts. 76–89 LIS), ETVE election, Netherlands vs. Luxembourg vs. Spain comparison.
View service Economic-Administrative Claim (Reclamación Económico-Administrativa)Economic-administrative claim (Arts. 226–249 LGT): TEAR vs. TEAC, 1-month mandatory filing deadline (Art. 235 LGT), automatic suspension for sanctions, guarantee-conditioned suspension for assessments, 78% success rate.
View service ETVE — Spanish Foreign Securities Holding EntityETVE (Entidad de Tenencia de Valores Extranjeros, Arts. 107–108 LIS): 95% exemption on dividends and capital gains from foreign subsidiaries, zero IRNR withholding on distributions to non-resident shareholders from exempt income.
View service Family Office Tax AdvisoryTax advisory for family offices and high-net-worth individuals: Art. 21 LIS (95% dividend exemption), ETVE (Arts. 107–114 LIS), Art. 4.Ocho IP wealth tax exemption, Art. 20.2.c ISD 95% succession reduction, SICAV regime.
View service Exit Tax — Spanish Latent Gains Tax on DepartureSpanish exit tax (Art. 95 bis LIRPF): €4M shareholding threshold, 10-year fiscal residence condition, EU/EEA 10-year automatic deferral, third-country 5-year deferral with guarantees, interaction with Beckham regime.
View service Form 210 — Non-Resident Income Tax (IRNR)Form 210 (IRNR) for non-resident property owners and investors in Spain: rental income (19% EU/EEA, 24% non-EU), imputed rental income, property sale capital gains, 3% buyer withholding (Form 211), double taxation treaty rate reductions.
View service Fiscal Representation for Non-Residents in SpainFiscal representation for non-residents in Spain (Art. 10 LIRNR): mandatory for non-EU/EEA residents, Form 210/216/296 management, permanent establishment compliance, double taxation treaty rates, UK post-Brexit obligations.
View service Form 720 — Overseas Assets DeclarationForm 720 overseas assets declaration (Ley 7/2012, reformed by Ley 5/2022 post-CJEU C-788/19): three blocks (bank accounts, securities, real estate), €50k threshold per block, 1 January–31 March filing window, current penalty regime.
View service Form 721 — Overseas Cryptocurrency Assets DeclarationForm 721 (Orden HFP/887/2023): mandatory cryptocurrency declaration for Spanish tax residents with €50k+ in assets at foreign exchanges (Binance, Kraken, Coinbase, OKX, Bybit). DAC8 from 2026. Not applicable to self-custody wallets.
View service Limited-Scope Tax Audit Defence (Comprobación Limitada)Expert defence in AEAT limited-scope tax audit proceedings (Arts. 136–140 LGT): preclusive effect of resolution, 6-month caducidad, strategic use of conformity vs. disagreement to close the matter definitively.
View service Pillar Two — Global Minimum Tax (Top-Up Tax)Pillar Two (Directive 2022/2523, Ley 7/2024): IIR, UTPR and QDMTT for groups with €750M+ consolidated revenue. Modelos 240/241/242 (Orden HAC/1198/2025). First declarations for 2024: deadline April–July 2026. CbCR safe harbour transition.
View service RIC — Canary Islands Investment ReserveRIC (Reserva para Inversiones en Canarias): up to 90% CIT base reduction (Art. 27 Ley 19/1994), eligible asset categories A1–D1, 3-year materialisation deadline, 5-year retention, RIC+ZEC combination. BMC Las Palmas office.
View service Startup Tax Advisory — Ley 28/2022 (Start-Up Act)Startup tax advisory under Spain's Ley 28/2022: 15% CIT for 4 years, 50% angel investor deduction (up to €100k), €50k employee stock option exemption, ENISA accreditation, 12-month CIT deferral.
View service Tax Adviser in BarcelonaTax advisers in Barcelona: tax planning for companies and groups, Corporate Income Tax, VAT, AEAT/TEARC inspections and 22@ startups.
View service Tax Adviser in Bilbao — Bizkaia Foral RegimeTax advisers in Bilbao: Bizkaia foral regime, foral Corporate Income Tax, Economic Agreement, and Hacienda Foral. Specialists in manufacturing, energy, and shipping.
View service Tax Adviser in ValenciaTax advisers in Valencia: tax planning, CIT, VAT, and AEAT inspections. Specialists in agri-food, logistics, and ceramic companies.
View service Tax Advisory in BarcelonaTax advisory in Barcelona: tax planning, CIT, Catalan regional IRPF, Large Fortunes Tax, ATCAT, and AEAT inspections with an assigned local member.
View service Tax Advisory in the Basque Country — Three Provincial TreasuriesTax advisory in the Basque Country: Basque Economic Agreement, Haciendas Forales of Bizkaia, Gipuzkoa, and Álava, foral CIT, foral IRPF, and connection points.
View service Tax Advisory in Bilbao — Basque Economic AgreementTax advisory in Bilbao: specialists in the Basque Economic Agreement, Bizkaia foral CIT (Foral Regulation 11/2013), Hacienda Foral, and connection points. Form 200B.
View service Tax Advisory in Las Palmas de Gran CanariaSpecialists in the Canary Islands Economic and Fiscal Regime (REF): ZEC (4% IS), RIC, IGIC, Canarian investment incentives, and international tax planning from Las Palmas.
View service Tax Advisory in MadridExpert tax advisers in Madrid: corporate tax planning, AEAT inspections, Comunidad de Madrid tax advantages, M&A, and international group structures.
View service Tax Advisory in MálagaTax experts in Málaga: non-resident tax (IRNR), Beckham law for expats, real estate capital gains, inheritance tax on the Costa del Sol, and Wealth Tax planning.
View service Tax Advisory in MarbellaTax advisers in Marbella for HNWIs, international investors, non-residents, and expats. Specialists in Wealth Tax, ISD, Beckham law, and luxury real estate taxation.
View service Tax Advisory in Navarra: Economic Agreement | BMCSpecialists in the Navarra Economic Agreement: CIT under Foral Law 26/2016, foral IRPF, Hacienda Foral de Navarra, and connection points for foral companies.
View service Tax Advisory in MurciaTax specialists in Murcia: agri-food taxation, agricultural cooperatives, corporate tax, VAT regimes, R&D&I deductions, and fiscal planning for Murcia Region businesses.
View service Tax Advisory Tenerife — Canary Islands Special RegimeTax advisory in Tenerife: ZEC (4% CIT), RIC (up to 90% base reduction), DIC, IGIC and the full Canary Islands Special Economic and Fiscal Regime (REF). BMC office in Las Palmas.
View service Tax Consolidation for Corporate GroupsTax consolidation regime for Spanish corporate groups (Arts. 55–75 LIS): ≥75% participation threshold, Modelo 222/220, immediate intragroup loss offset, and management of pre-incorporation tax losses.
View service AEAT Tax Inspection ProcedureComprehensive defence in AEAT tax inspection proceedings: representation, submissions, conformity and non-conformity assessments, and appeal strategy (arts. 141-159 LGT, RGGIT RD 1065/2007).
View service Tax Liability Derivation Defence (Derivación de Responsabilidad Tributaria)Defence against AEAT tax liability derivation proceedings (Arts. 41–43 LGT): joint liability (Art. 42) vs. subsidiary liability (Art. 43), directors, shareholders, STS 594/2025 causal link requirement, 15-day hearing window.
View service Tax Judicial Review (Recurso Contencioso-Administrativo)Tax judicial review (Ley 29/1998 LJCA): 2-month deadline from TEAR/TEAC resolution, Juzgados CA / TSJ / Audiencia Nacional competence, cassation to Tribunal Supremo (Sala 3ª) via Art. 88 LJCA interés casacional.
View service ZEC — Canary Islands Special Economic Zone (4% CIT)ZEC Canary Islands (RDLeg 1/2019): 4% corporate income tax rate, 5 employees minimum, €100k investment, eligible CNAEs. Registration deadline 31 December 2026. RIC + REF combination. BMC Las Palmas and Tenerife.
View servicePublished analysis
Articles and reports published by Ana
DAC8: Automatic Exchange of Information on Crypto Assets
30 May 2026 · DAC8, crypto-assets
ZEC Canary Islands: Countdown to December 2026
29 May 2026 · ZEC, Canarias
Inheritance Tax Spain by Region 2026: Rates, Reliefs & Regional Comparison
28 May 2026 · inheritance-tax, gift-tax
Beckham Law vs Standard IRPF Regime 2026: Comparison with Numerical Examples
26 May 2026 · tax-fiscal/beckham-law, IRPF
Beckham Law Year 7: your exit-planning guide
26 May 2026 · fresh-start-law, impatriates
The Beckham Law 6-Month Deadline Trap: What Nobody Tells You Before Filing Form 149
25 May 2026 · tax-fiscal/beckham-law, form-149
Spain's Modelo 720 After the ECJ Ruling (C-788/19) and Law 5/2022: Complete Guide 2026
25 May 2026 · fiscal/informacion-bienes-exterior, modelo-720
Spain IRPF 2026 Tax Brackets for New Residents: State Scale + Regional Rates Explained
25 May 2026 · tax-fiscal/irpf, tax-brackets
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