Insights
Technical analysis of international taxation, estate planning, real estate law and family business, written by the Lex·on team.
Tax · Wealth
Limited liability, the three million Balearic allowance, foreign companies holding Spanish property and the solidarity tax on large fortunes.
Tax · Expatriates
Conditions for Spain's article 93 inbound regime, the six-month election deadline, the 24% rate and the treaty residence problem it creates.
Tax · Tourism
The ETV licence, tourist places and the taxation of holiday letting in Mallorca: property income or business, VAT, platform fees and stay tax.
Tax · Non-Residents
How the 3% withholding works when a non-resident sells Spanish property, how the gain is computed, the deadlines and how to reclaim the excess.
Tax · Succession
The scope of the 100% Balearic inheritance tax relief, the valuation conditions, the treatment of gifts and how non-resident heirs claim it.
Tax · Non-Residents
How imputed income is calculated for non-resident owners of Spanish property, which rate applies and how the new 2026 filing deadlines work.
Tax · Wealth
The Spanish tax authorities confirm that paying the premium with shares is a disposal: the latent gain is taxed in the year of the contribution.
Tax · Corporate
Spain's tax authority keeps income and expenses from synthetic PPAs outside the article 16 limitation, provided they are booked as hedging instruments.
Tax · Corporate
Spain's tax authority confirms that a cash-settled incentive plan is booked over years but only deducted in the year the plan is finally settled.
Tax · Family Business
Spain's tax authority denies rollover relief on the demerger of a company with 28 let properties between two families, for lack of separate business units.
Tax · Corporate
Spain's tax authority sets when insurance proceeds for a written-off company car are taxed for corporate income tax, and what it leaves unanswered.
Tax · Real Estate
One deed, two stamp duty charges. Spain's tax authority sets the building declaration base at construction cost and the horizontal property base at value.
Tax · Corporate
Binding ruling V0867-26 examines a loan waiver between companies of the same shareholder: a non-deductible expense, taxable income and the role of ownership percentages.
Tax · Real Estate
If a co-owner is non-resident, whoever receives the property must withhold 3% and pay it in using form 211. If not, the property remains charged with the debt.
Tax · Real Estate
Binding ruling V0623-25 sets out the complete framework for the dissolution of co-ownership: when stamp duty applies, when transfer tax applies and when a gift subject to inheritance tax arises.
Tax · International
The tax authorities examine a US LLC with a single resident member in ruling V0848-26: reporting obligations, valuation rules and the residence and CFC risks it leaves unresolved.
Tax · Succession
Ruling V0767-26 confirms that a legacy received by a company is taxed under corporate income tax at market value, not under inheritance tax. We analyse its effects.
Tax · Restructurings
Requirements of article 87.1 of the corporate income tax act, the 5% threshold co-owner by co-owner, valid economic reasons and the burden of proof left open by ruling V0770-26.
Tax · Income tax · Inheritance tax
The succession agreement is an estate planning tool with a specific tax regime in the Balearics. We analyse its treatment under income tax, inheritance tax and its practical implications.
Real Estate · Non-residents
Transfer tax, non-resident income tax, municipal capital gains tax and formal obligations. What a foreign buyer needs to know before signing before a Spanish notary.
Family Business · Inheritance tax
The relief exists, but its application is subject to strict conditions. We review the substantive requirements and the most common errors that give rise to liabilities.
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