Bulletin · Spanish Tax Law

Tax Law
Barcelona

Spanish Tax Journal

Analysis
Doctrine · Case law

Spanish Tax Journal is a working notebook on Spanish tax law. We comment on judgments of the Supreme Court and the Court of Justice of the European Union, binding consultations of the Directorate-General for Taxes, resolutions of the Central Economic-Administrative Tribunal, and the gradual consolidation of administrative doctrine, always working from the primary source.

The subjects we return to most often are those we handle in practice: international taxation, the Beckham regime, residency disputes, crypto-assets, trusts and foreign private foundations, and the planning of foreign investment into Spain.

It is written for taxpayers and other professionals working through their own cases. The intention is to help them weigh what the rules in force permit, how the case law reads them, and what the tax authority does with them in practice. Much of Spanish tax law remains open to interpretation, and we try to write about it accordingly: the competing readings on the table, the risks they carry, and the limits of what can be said with certainty.

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Analysis 27.05.2026

Interposing a holding company as administrator can cause the rest of the family group to lose the family-business exemption

Analysis of binding consultation DGT V-0354/2026, of 18 February 2026: interposing a holding company that exclusively assumes the management functions of the operating entity causes the members of the family group holding direct stakes in the operating entity to cease meeting the requirement of …

Empresa familiar·DGT · holding · empresa familiar
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