Areas of expertise
Specializations
- Cross-border restructuring
- Tax treaty application
- Pillar Two (GloBE) compliance
Education
- Master in Taxation, CEU San Pablo
- Law Degree, University of Granada
Languages
Biography
Fernando brings sixteen years of experience in international taxation, nine of which he spent in the tax practice of a Big Four firm in Madrid before joining BMC in 2019. He leads international tax engagements for corporate groups with cross-border operations.
His core specialities are ETVE holding structures, tax treaty planning, and Pillar Two (GloBE rules) implementation under the OECD framework. He has structured operations across more than fifteen jurisdictions, coordinating local tax teams in Europe, Latin America, and Southeast Asia. His background in an international firm gives him fluency across both the substantive and compliance dimensions of multi-jurisdictional work.
Fernando is also BMC’s primary contact for German and Austrian companies entering the Spanish market. His fluent German and deep familiarity with the tax systems of both countries significantly ease communication with home-country advisers and with the finance teams of these groups directly. A member of AEDAF and IFA Spain, he participates regularly in specialist forums on international taxation and the digital economy, and keeps the firm’s methodology aligned with evolving OECD standards. His combination of Big Four technical depth and boutique advisory agility is consistently cited by clients as a differentiating factor.
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Services led
Practice areas where Fernando serves as lead advisor or active contributor
Fiscal 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 International TaxTax advisory for cross-border operations, international expansion, and multi-jurisdictional compliance.
View service Italian Freelancer Tax Structuring — Italy to Spain TransitionTechnical analysis and execution support for Italian freelancers who have exceeded the €85,000 forfettario threshold and are planning a tax-efficient transition: Italian SRL, holding with art. 87 TUIR participation exemption, art. 166 TUIR exit tax, and Spain's Beckham regime.
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 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 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 Special TerritoriesExpert advisory on the tax regimes of the Canary Islands, Ceuta, and Melilla to maximise available incentives.
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 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 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 ComplianceComprehensive management of periodic tax obligations: return filing, tax calendar, compliance audits, and representation before the Spanish Tax Agency (AEAT).
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 Litigation & DisputesDefence in AEAT inspections, appeals against tax assessments before TEAR/TEAC, contentious-administrative proceedings and Tribunal Supremo casation in Spain.
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 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.
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