Spain Holding Company (ETVE)

Spanish Foreign Securities holding company (Entidad de Tenencia de Valores Extranjeros (ETVE)) can provide an effective solution to the reorganisation problems faced by companies operating internationally. The flexibility and numerous tax benefits make a Spanish holding company an ideal vehicle for investments in Europe and Latin America.
Advantages of a Spain Holding Company
1.	A Spain holding company has total participation exemption for dividends and capital gains realized on the disposal of shares with no, or low, withholding tax on distribution of non-Spanish source dividends. Dividends and capital gains earned by qualified non residential companies in Spanish Territory, shall be tax exempt in order to avoid international double taxation.
2.	The extensive and growing network of double taxation treaties provide 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.
3.	Without requiring administrative authorization, the setup procedures for a Spain holding company are straightforward, the only requirement being to notify the Tax Authorities. Spanish Tax Authorities may require an ETVE to provide documents verifying all legal requirements have been fulfilled. Healy Consultants can prepare these documents for you.
4.	A Spanish holding company, controlling at least 10% of the shares of a EU subsidiary for a minimum period of 12 months, results in any dividends remitted by the EU subsidiary to the Spanish holding company being exempt of withholding taxes.
5.	A Spain holding company enjoys full deductibility of interest payments on funds borrowed for foreign company participation.
Disadvantages of a Spain Holding Company
1.	A Spanish holding company ETVE should have a minimum participation of 5% in the capital of the foreign company, or the participation should be higher than €6 million Euro.
2.	If foreign source dividends are exempt from tax in Spain, the Spain holding company cannot include the depreciation of the participation corresponding to those dividends in the taxable base.

Contact Us
For more information on Spain company formation, please email email@healyconsultants.com or telephone us at (+65) 6735 0120.
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