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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.

More information can be found by visiting our website at www.ibcf.com, or by emailing us at [email protected].

Previous issues of the IBCF Newsletter can be found at: http://www.ibcf.com/news/newshome.php

About IBCF:
International Business Company Formation, Inc. assists legal professionals with company formation, both internationally and offshore, and with registered agent and corporate document retrieval services throughout the world.

International Business Company Formation is an affiliate of National Registered Agents, Inc., a fully licensed professional Registered Agent for thousands of business entities, large and small, throughout the entire United States.

International Business Company Formation, Inc. is located in the historic district of Tappan, New York, approximately thirty minutes from midtown Manhattan.

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