Lucia Mendez Ortega

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.

End-to-end management of Spain's special tax regime for inbound workers: eligibility, application, and optimisation.

Corporate 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.

Planning and compliance for Spanish corporate income tax: base optimisation, deductions, instalment payments and audit defence.

Specialist tax advisory on cryptocurrencies, NFTs, DeFi, and other digital assets for individuals and businesses.

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.

ETVE (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.

Spanish 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.

Tax 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.

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.

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.

Form 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.

Form 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.

Spanish Inheritance and Gift Tax (ISD) planning: family business exemption, regional variations, donation structures and non-resident inheritance tax.

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

Technical 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.

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.

Advisory and compliance for Spain's Non-Resident Income Tax for individuals and entities without Spanish tax residency.

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.

R&D and technological innovation tax deductions (Art. 35 LIS), Patent Box regime and Binding Motivated Report for maximising Spain's innovation tax incentives.

Expert advisory on the tax regimes of the Canary Islands, Ceuta, and Melilla to maximise available incentives.

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.

Tax advisers in Barcelona: tax planning for companies and groups, Corporate Income Tax, VAT, AEAT/TEARC inspections and 22@ startups.

Tax advisers in Bilbao: Bizkaia foral regime, foral Corporate Income Tax, Economic Agreement, and Hacienda Foral. Specialists in manufacturing, energy, and shipping.

Tax advisers in Valencia: tax planning, CIT, VAT, and AEAT inspections. Specialists in agri-food, logistics, and ceramic companies.

Tax advisory in Barcelona: tax planning, CIT, Catalan regional IRPF, Large Fortunes Tax, ATCAT, and AEAT inspections with an assigned local member.

Specialists in the Canary Islands Economic and Fiscal Regime (REF): ZEC (4% IS), RIC, IGIC, Canarian investment incentives, and international tax planning from Las Palmas.

Expert tax advisers in Madrid: corporate tax planning, AEAT inspections, Comunidad de Madrid tax advantages, M&A, and international group structures.

Tax advisers in Marbella for HNWIs, international investors, non-residents, and expats. Specialists in Wealth Tax, ISD, Beckham law, and luxury real estate taxation.

Specialists in the Navarra Economic Agreement: CIT under Foral Law 26/2016, foral IRPF, Hacienda Foral de Navarra, and connection points for foral companies.

Tax 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.

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.

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.

Legal and efficient tax strategies to reduce your company's tax burden and protect your personal wealth.

Transfer pricing policies and documentation that protect your group against audits and double taxation.

Planning for Spanish Wealth Tax (IP) and the Solidarity Tax on Large Fortunes (ITSGF): family business exemption, holding structures, Beckham Law interaction and exit tax.

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.