Fundación Privada Extranjera

Foreign private foundation
TEAC· 02.05.2026

Law 49/2002 regime and non-resident foundations: prior election and formal notification, no shortcuts

The TEAC confirms that the special tax regime of Law 49/2002 is elective: non-resident foundations must exercise prior election and formal notification before the chargeable event. Retroactive application is not …

Foreign foundation
Foreign private foundation
TEAC· 02.05.2026

The tax regime of Law 49/2002 does not apply automatically to non-resident foundations: the TEAC requires the prior election to exclude taxation under the IRNR

Foreign foundation
Foreign private foundation
DGT· 25.02.2016

The Liechtenstein Stiftung has autonomous legal personality under Spanish law: the contribution of Spanish real estate triggers inheritance and gift tax by in rem obligation