Company & Subsidiary Incorporation
SL or branch setup, NIF and registered office, notarial process and Registro Mercantil registration, addressing tax residence from day one.
Corporate Tax for International Business
Corporate Tax in Spain for Foreign Companies & International Groups
Spanish corporate tax advice for foreign companies opening a subsidiary or branch, startups incorporating in Spain, and international groups structuring cross-border holdings, transfer pricing and profit repatriation — coordinated with our corporate and immigration practices when company law or executive relocation is also involved.
Law Cappital is directed by Jorge Lacasa Alesón, Managing Partner
Spanish Tax & International Lawyer · ICAM nº 135311
Previously at Grant Thornton & Vialto Partners
Corporate tax, in numbers
What a Spanish Subsidiary Actually Pays
25%Standard corporate tax (Impuesto sobre Sociedades) rate
15%Reduced rate for newly incorporated companies, first 2 profitable years
15% / 4yrReduced rate for ENISA-certified startups, first 4 profitable years
21%Standard VAT (IVA) rate
Cross-border structuring, in numbers
What Matters for International Groups
95%Exemption on qualifying dividends & capital gains from subsidiaries
19%Default withholding on dividends/interest to non-residents, often reduced by treaty
30%Cap on net interest deductible against operating profit (EBITDA)
90+Double tax treaties signed by Spain, including the US and UK
Figures reflect the regimes as generally applied at time of writing and depend on your specific structure — we confirm your exact numbers in the first consultation.
Note on investor visas: Spain's investor ("golden visa") residency route was abolished in April 2025. Executives and shareholders relocating to run the Spanish operation now typically need an intra-company transfer, an entrepreneur visa, or — once resident — may qualify for the Beckham Law's 24% flat tax rate. Our immigration team can advise on the right route.
How we help
Corporate Tax Services for Companies Entering Spain
Tax is our core focus for foreign companies, but incorporation, contracts and shareholder structuring are handled together with our corporate law practice.
Corporate Tax Compliance
Impuesto sobre Sociedades filings, quarterly instalment payments and coordination with your accounting team on annual accounts.
Transfer Pricing
Master file / local file documentation and intercompany agreements for transactions between your Spanish entity and the rest of the group.
Holding Companies & International Structures
Spanish holding company structuring (ETVE and the general participation exemption) for groups with foreign subsidiaries.
VAT & Indirect Tax
Spanish VAT registration, reverse-charge analysis and cross-border supply chain questions for non-established businesses.
Foreign Investment Screening
Assessing whether Spain's FDI screening regime applies to your sector and investor profile before you close.
Corporate & Commercial Law
Bylaws, shareholder agreements, director appointments and other company-law matters, handled by our corporate practice alongside your tax setup.
Explore Corporate Services →Relocating an Executive
If you're sending someone to run the Spanish operation, their personal tax position — including possible Beckham Law eligibility — should be planned alongside the company's.
Check Beckham Law Eligibility →
Who this is for
Common Reasons Companies Come to Us
International clients usually fall into one of these situations. Tell us which one fits and we'll take it from there.
Opening a subsidiary or branch in Spain
A foreign company setting up its first Spanish entity, choosing between an SL subsidiary and a branch, and planning the tax and corporate structure from the start.
Explore Setup Services →A startup incorporating in Spain
An international founder incorporating in Spain to access the EU market or Spanish/European investors, and assessing eligibility for the Startups Law's 4-year reduced tax rate.
Explore Startup Structuring →Structuring a Spanish holding company
An international group considering Spain as a jurisdiction to hold foreign subsidiaries, using the participation exemption on qualifying dividends and capital gains.
Explore Holding Structures →Relocating an executive to run the operation
A group sending a director or key employee to manage the new Spanish entity, where the individual's tax residence and possible Beckham Law treatment need coordinated planning.
Check Beckham Law Eligibility →
Common questions
Questions Foreign Companies Ask Us Most Often
Structure, tax rate and cross-border repatriation questions often overlap. These are some of the issues that usually come up first.
Should our company set up a Spanish subsidiary (SL) or a branch?
Both a subsidiary (a separate Spanish company, typically an SL) and a branch (an extension of the foreign parent) can operate in Spain and are both taxed at the same 25% corporate rate on their Spanish profits. The right structure usually depends on liability protection, how profits will be repatriated, and reporting obligations in the parent's home jurisdiction, not on the tax rate alone.
What corporate tax rate will our Spanish subsidiary pay?
The standard Spanish corporate tax (Impuesto sobre Sociedades) rate is 25%. Newly incorporated companies can generally apply a reduced 15% rate for their first profitable tax period and the following one, unless they qualify as an equity company or are part of a corporate group. Companies certified as startups under Spain's Startups Law can apply the 15% rate for 4 years instead of 2, subject to ENISA certification and eligibility conditions.
Do we need a Spanish VAT number if we don't have a permanent establishment here?
Often yes. A non-resident company can be required to register for Spanish VAT (IVA, standard rate 21%) for certain transactions even without a permanent establishment, particularly for supplies of goods or services located in Spain. Whether registration and reverse-charge rules apply depends on the specific transaction and your customers.
How are dividends taxed when we repatriate profits to our parent company?
Under Spanish domestic law, dividends paid to a non-resident parent are generally subject to a 19% withholding tax. This is frequently reduced or eliminated under the EU Parent-Subsidiary regime, broadly for EU/EEA parents holding at least 5% for one year, or under an applicable double tax treaty. Spain has signed more than 90 double tax treaties, including with the US and UK.
Are dividends and capital gains from a Spanish holding company's subsidiaries taxed?
Spain applies a participation exemption: dividends and capital gains from qualifying shareholdings, generally at least 5%, held for at least one year, in an operating company, can be up to 95% exempt from Spanish corporate tax, provided a foreign subsidiary is subject to a tax similar to Spanish corporate tax at a nominal rate of at least 10%. This is the basis of Spain's use as a holding jurisdiction for international groups.
Does Spain's foreign investment screening regime affect us?
It can. Spain screens certain foreign investments in sensitive sectors, such as energy, telecoms, transport, health, media, dual-use technology and financial infrastructure, and additional scrutiny can apply to investors from outside the EU/EFTA. Whether prior authorisation is required depends on your sector, the size of the investment and the investor's origin, and should be checked before closing, not after.
General information only, not personalised legal or tax advice. Share your situation and we'll tell you what needs to be reviewed.
Take the next step
Planning to Set Up or Invest in Spain?
Tell us about your structure — subsidiary, branch, holding company or investment — and we'll point you in the right direction.