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EU holdcos using the Spanish ETVE regime, Spain

The Spanish Holding ETVE regime gives near full participation exemption on qualifying foreign dividends and capital gains, with no minimum holding period beyond 12 months. It works well for groups holding LATAM subsidiaries from inside the EU.

Spanish Holding ETVE regimeParticipation exemptionLATAM treaty depth
Start setup {placement} 4 min · no card required
Corp tax
25%
Fastest setup
2 weeks
Tax treaties
95
Region
Europe

What you'll need

  • No resident director required
  • Local registered office required
  • No substance requirement
  • Minimum capital: EUR 1
  • Administrative language: Spanish
  • Legal system: Civil law

Tax and treaty profile

  • Corporate tax 25%
  • Effective rate ~23%
  • Tax treaties 95
  • VAT rate 21%
  • Withholding on dividends 19%
Key treaty partners
FranceGermanyUKUSAPortugalItaly

Banking and payments

  • Banking is straightforward
  • Stripe supported
  • Wise supported
  • Crypto banking available
  • EMI license framework available

Considerations

If raising US VC is the priority

Spanish SLs and SAs are not on the term sheet menu of US tier-1 funds. Most Spanish startups that raise institutional capital flip to a Delaware C-corp before Series A.

SL/SA off term sheetsDelaware flip pre Series A