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Strategic tax architecture in Spain for international groups

  • Writer: Rolf Silver
    Rolf Silver
  • Oct 22
  • 1 min read

I just got off a call with a CFO who'd been operating in Spain for eight months. They had a local accountant, filed everything on time and thought they were sorted.

Then Hacienda sent a notice questioning their entire inter-company structure. The issue?

Their accountant was excellent at compliance filing but had never worked with international groups before, so they'd missed the strategic tax architecture that Spanish authorities expect from day one.

Here's what most finance leaders don't realise: Spain doesn't just want your paperwork filed correctly.

They want to see that your structure makes commercial sense, that your transfer pricing reflects genuine substance, and that your entity setup aligns with your actual operations.

A local accountant can handle the forms, but if they've never advised international businesses, they won't flag the structural gaps that trigger audits later.

The question isn't whether your accountant is good, it's whether they understand what Hacienda is really looking for. Do they know the best strategic tax architecture in Spain for international groups?

++ I'm Rolf, I talk about business compliance, Spanish market entry and accounts in Spain's complex business landscape. Follow me for insights, tips and advice about cross-border accountancy.

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