🇪🇸 Spain Company Formation
ETVE holding regime with 95% participation exemption. Beckham Law at 24% flat PIT. The EU's strongest LatAm treaty network with 93 tax treaties.
Updated April 2026
Corp Tax
25%
ETVE Effective
~1.25%
Beckham Law PIT
24% flat
Tax Treaties
93
Start-ups CIT
15%
Tax System
Rates and incentives
| Tax | Rate | Note |
|---|---|---|
| Corporate income tax | 25% | Standard rate. SMEs 23% (2026). Micro-enterprises 19%/21%. Newly created companies 15%. |
| ETVE — foreign dividends | ~1.25% | 95% participation exemption on qualifying foreign dividends and capital gains. 5%+ holding for 1+ year. |
| Beckham Law PIT | 24% | Flat rate on Spanish-source income up to EUR 600,000 for 6 years. 47% above. |
| Patent Box | ~10% | 60% income reduction on qualifying IP income. OECD nexus approach compliant. |
| Withholding — dividends | 19% | EU Parent-Subsidiary Directive applies (0% for qualifying EU parents). Treaty rates as low as 0%. |
| R&D tax credit | 25–42% | Generous credit on qualifying R&D expenditure. Innovation credit at 12%. |
Why Spain
Key advantages
ETVE — the EU's best holding regime for LatAm
95% participation exemption on foreign dividends and capital gains. Combined with Spain's 93 DTAs — the most extensive network in Latin America — creates a uniquely efficient EU holding structure.
Beckham Law — 24% flat PIT for 6 years
Available to relocated workers, entrepreneurs, and digital nomad visa holders. Flat 24% on Spanish-source income. Valid for the year of relocation plus 5 additional years.
15% CIT for start-ups and new companies
Qualifying start-ups pay 15% CIT for the first 4 profitable years. Combined with R&D credits of 25–42%, the effective burden can be very low for tech companies.
93 double tax treaties — strongest LatAm coverage
DTAs with Brazil, Mexico, Colombia, Argentina, Chile, Peru, and all major LatAm markets. Plus full EU, US, UK, and Asian coverage.
EU single market access with Canary Islands ZEC option
Full EU membership. Canary Islands Special Zone (ZEC) offers 4% CIT for qualifying businesses. Strong passport — 190 visa-free countries.
What We Build
Full scope of implementation
- ✓Spain SL company registration with notarized deed
- ✓NIE application for foreign directors and shareholders
- ✓ETVE holding status registration and compliance
- ✓Beckham Law election filing within 6-month window
- ✓Corporate bank account — full KYC file and compliance dossier
- ✓Annual compliance — corporate tax, quarterly VAT and IRPF filings
- ✓Transfer pricing documentation for related-party transactions
Who This Is For
Ideal client profiles
2025 – 2026
What has changed
⚠ Golden Visa for real estate — abolished April 2025
Spain eliminated the real estate investment route for Golden Visa. Other investment routes and the Digital Nomad Visa remain available.
Progressive CIT reductions for SMEs — 2025 to 2028
SME rate reducing from 25% to 21% and micro-enterprise rate from 25% to 17% in phases through 2028.
Pillar Two — fully implemented
IIR from FY 2024, UTPR from FY 2025. 15% global minimum tax for qualifying MNE groups.
Common Questions
FAQ
What is the ETVE regime and who should use it?
ETVE (Entidad de Tenencia de Valores Extranjeros) is Spain's holding company regime. It provides a 95% participation exemption on dividends and capital gains from qualifying foreign subsidiaries (5%+ holding, 1+ year, subject to tax at 10%+ nominal rate). Ideal for EU holding structures with LatAm operations.
How does the Beckham Law work?
Relocated workers, entrepreneurs, and start-up directors can elect a flat 24% PIT on Spanish-source income for 6 years (year of arrival + 5). Must not have been Spanish tax resident in the prior 5 years. Digital Nomad Visa holders also qualify. Election must be made within 6 months of work permit registration.
Is Spain viable for e-commerce businesses?
Only with Beckham Law or ETVE structuring. Standard effective tax burden without incentives reaches 40%+ when combining 25% CIT, wealth tax, and social contributions. Beckham Law plus start-up 15% CIT can create a competitive structure for qualifying founders.
Can LatAm nationals get Spanish citizenship faster?
Yes — nationals of Latin American countries, Philippines, Equatorial Guinea, Andorra, and Portugal can apply for citizenship after just 2 years of legal residence, compared to 10 years for other nationalities.