EMCCANARIAS

ESTABLISH A SPANISH HOLDING COMPANY
The Tax Advantages of Spanish Holding Companies (ETVEs)

The Spanish Holding Companies , which are called ETVE "Entidades de Tenencia de Valores Extranjeros", are the Holding Companies with the most advantageous taxation in Europe.

"ETVE" is a regular entity in the form of a corporation or limited liability company that enjoys great tax advantages, in particular:

  • Benefit from the exemption from taxation of inbound dividends from foreign investee companies. 
  • Benefit from the exemption from taxation of dividends paid to Holding Company shareholders not resident in Spain.
  • Gnonresident shareholders are not taxed in Spain.
  • ETVE income from subsidiaries can also be repatriated to the shareholder's country without being subject to Spanish tax or any withholding tax.

THE ADVANTAGES OF A SPANISH HOLDING COMPANY IN THE CANARY ISLANDS

The most advantageous tax regime in Europe for holding companies is that of Spain, which covers holding companies Spain, which are called (ETVE - "Entidades de Tenencia de Valores Extranjeros").

This type of company has special characteristics that lead it to be a valuable tool for use in business groups in the international arena... 

Le holding companies Spanish "ETVEs" are widely used by companies to structure their own corporate holdings, using Spain as a base.

The advantage of this corporate structure is linked, as is usually the case with holding companies, in a special tax regime for taxing dividends.

"ETVE" is a simple Limited Liability Company (Sociedad Limitada) with a share capital of €3,000.

    • The Spanish holding company pays tax on dividends received from its investees with tax exemption on 95% of the dividends received.
      It only taxes the remaining 5% at the rate of 25%.
      Therefore, the effective taxation on the total dividends received is 1.25%;
    • Corporate Tax Exemption for Dividends and Capital Gains (capital gains from the sale of shares in subsidiary companies).
    • Full exemption of dividends distributed by the holding company to nonresident shareholders wherever they are (except dividends received from tax havens).

Opening a Holding Company in Spain is even more convenient for those companies that intend to hold stakes in companies located in countries with which Spain has signed treaties to avoid double taxation, particularly with Latin American countries but also U.S.A., United Arab Emirates emoluments and many others.

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