The Spanish Holding Company or ETVE
The Spanish regime for international holding companies compares favourably with traditional European centres such as Luxembourg, Netherlands and Belgium. It can provide effective solutions to the reorganisation problems required for companies operating internationally. A Spanish holding company is known as an "ETVE". The regime has gained the approval of the European Commission.
The main tax benefits of a Spanish Holding Company are:
* Total participation exemption for dividends and capital gains realized on the disposal of shares.
* Absence of a withholding tax on distribution of non-Spanish source dividends;
* Full deductibility of interest payments;
* No capital duty on the issue of share capital for entities established in certain provinces, and on share-for-share contributions.
* Exemption of overseas branch income.
* Availability of pre-transaction rulings.
These tax benefits, along with the added flexibility provided by the recently issued final "check-the-box" regulations in the United States, make a Spanish Holding Company an ideal vehicle for investments in Europe and Latin America.
In fact, more and more companies use Spain as a launching step to Latin America.
Spain's extensive and growing double taxation treaty network means that it exercises substantial leverage in reducing withholding taxes on dividends remitted to a Spanish holding company by a foreign subsidiary located in a double taxation treaty country.
To set up an ETVE it is not necessary to get an administrative authorization, only to notify the Tax Authorities.
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