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Advisory for Spain's industry competing in global markets

We advise manufacturers, industrial groups and companies in Spain's manufacturing sector on tax, legal and corporate matters, from value chain optimisation to industrial restructuring and international expansion.

125.250
active companies in Spain
2.208.518
registered workers (SS)
695.9B€
annual revenue (INE)
45,6%
5-year survival rate
7,0%
sector gross margin
7,6%
EU business share

Source: cifex · Seguridad Social · INE EEE · INE DIRCE

100+
industrial groups advised
15+
industrial restructurings supported
22+
years of sector experience

Spain’s manufacturing industry is one of the pillars of the national economy: with more than 125,250 active companies and 2,208,518 workers registered with Social Security, it generates aggregate revenue exceeding €695.9 billion and holds a 7.6% share within the industrial fabric of the European Union. The sector’s average gross margin stands at 7.0%, which demands highly refined financial and tax management to preserve profitability in an environment of elevated energy costs and intense international competition. The five-year survival rate of 45.6% reflects the severity of the industrial cycle and the importance of building a robust corporate structure from the earliest stages of growth.

At BMC we advise component manufacturers, steel groups, chemical companies, machinery manufacturers, automotive groups and other industrial operators on their tax, legal and corporate advisory needs. Our services include tax planning for industrial groups with international presence — transfer pricing, profit repatriation, value chain optimisation —, advice on industrial restructurings (ERE/ERTE, liquidations, subsidiary mergers), M&A transactions in the sector and the management of national and European industrial grants.

Industrial companies investing in automation, robotics or the digitalisation of their processes can benefit from R&D tax deductions that within Corporate Tax reach between 25% and 42% of eligible expenditure. Programmes such as the PERTE Chip, the PERTE Agroalimentario or just transition funds also offer non-repayable financing for green and digital transformation projects. Correctly identifying and articulating these incentives can make the difference between a viable project and one that is not.

We also advise on environmental compliance — environmental authorisations, waste liability, EU ETS compliance for CO2 emissions — and on energy and raw material supply contract management, which has grown increasingly complex in the current price volatility environment. With a 7.6% share of the European market and a revenue volume that places Spanish industry among the top ten in the EU, the opportunities for international growth are real, and BMC accompanies its clients at every step of that expansion.

Key services for manufacturing companies

Tax planning for manufacturing groups must address R&D+i deductions (articles 35 LIS), which allow deductions of 25-42% on qualifying R&D expenditure and 12% for technological innovation activities. Investment in robotics, additive manufacturing, IoT sensor networks and digital twins can qualify as technological innovation or R&D depending on their nature. Obtaining a binding motivated report from CDTI is recommended for larger programmes to protect the deduction in AEAT inspections.

Transfer pricing documentation for manufacturing groups must cover inter-company supply contracts between manufacturers and group distributors, the remuneration of contract and toll manufacturers, IP licensing arrangements for patents, trade marks and know-how, and shared service centre charges. AEAT has intensified transfer pricing audit activity in manufacturing, making robust annual documentation a priority.

Employment law for industrial companies involves sector collective agreements (metalurgia, química, alimentación and many others), management of shift work and overtime, health and safety compliance in industrial environments and ERE procedures for seasonal or structural workforce adjustments. The implementation of the Equality Plan and salary register obligations for companies with more than 50 employees adds additional compliance requirements.

Regulatory challenges for manufacturing

ESG and sustainability reporting is transforming the manufacturing sector. CSRD requires large manufacturers to report under ESRS standards from 2026; the EU Taxonomy classifies manufacturing processes as sustainable or not for green finance; and the Carbon Border Adjustment Mechanism (CBAM) creates new import costs for carbon-intensive materials. We advise manufacturing firms on developing CSRD-aligned reporting frameworks, EU Taxonomy assessments and green finance structuring.

The EU’s industrial policy agenda — including the European Chips Act, the Net Zero Industry Act and the Critical Raw Materials Act — creates new subsidy and compliance frameworks that manufacturing companies need to monitor and leverage. Grants management for IPCEI (Important Projects of Common European Interest) in strategic industrial sectors and PERTE (Strategic Projects for Economic Recovery and Transformation) in Spain are areas where BMC’s experience adds significant value.

Spain’s industrial sector generated €258 billion in production value in 2024, with the automotive sector, agri-food industry, chemicals and metal manufacturing as the largest subsectors. Manufacturing exports reached €320 billion, growing 4% year-on-year. Labour productivity grew 3.2% in real terms, driven by automation investment and the adoption of AI planning and production control tools. Nearshoring of supply chains from Asia to Southern Europe — particularly in automotive components and electronics — is creating new manufacturing investment in Spain and Portugal.

Key services for manufacturing companies

Tax planning for manufacturing groups must address R&D+i deductions (articles 35 LIS), which allow deductions of 25-42% on qualifying R&D expenditure and 12% for technological innovation activities. Investment in robotics, additive manufacturing, IoT sensor networks and digital twins can qualify as technological innovation or R&D depending on their nature. Obtaining a binding motivated report from CDTI is recommended for larger programmes to protect the deduction in AEAT inspections.

Transfer pricing documentation for manufacturing groups must cover inter-company supply contracts between manufacturers and group distributors, the remuneration of contract and toll manufacturers, IP licensing arrangements for patents, trade marks and know-how, and shared service centre charges. AEAT has intensified transfer pricing audit activity in manufacturing, making robust annual documentation a priority.

Employment law for industrial companies involves sector collective agreements (metalurgia, química, alimentación and many others), management of shift work and overtime, health and safety compliance in industrial environments and ERE procedures for seasonal or structural workforce adjustments. The implementation of the Equality Plan and salary register obligations for companies with more than 50 employees adds additional compliance requirements.

Regulatory challenges for manufacturing

ESG and sustainability reporting is transforming the manufacturing sector. CSRD requires large manufacturers to report under ESRS standards from 2026; the EU Taxonomy classifies manufacturing processes as sustainable or not for green finance; and the Carbon Border Adjustment Mechanism (CBAM) creates new import costs for carbon-intensive materials. We advise manufacturing firms on developing CSRD-aligned reporting frameworks, EU Taxonomy assessments and green finance structuring.

The EU’s industrial policy agenda — including the European Chips Act, the Net Zero Industry Act and the Critical Raw Materials Act — creates new subsidy and compliance frameworks that manufacturing companies need to monitor and leverage. Grants management for IPCEI (Important Projects of Common European Interest) in strategic industrial sectors and PERTE (Strategic Projects for Economic Recovery and Transformation) in Spain are areas where BMC’s experience adds significant value.

Spain’s industrial sector generated €258 billion in production value in 2024, with the automotive sector, agri-food industry, chemicals and metal manufacturing as the largest subsectors. Manufacturing exports reached €320 billion, growing 4% year-on-year. Labour productivity grew 3.2% in real terms, driven by automation investment and the adoption of AI planning and production control tools. Nearshoring of supply chains from Asia to Southern Europe — particularly in automotive components and electronics — is creating new manufacturing investment in Spain and Portugal.

Glossary

Key Sector Terms

EBITDA

EBITDA (Earnings Before Interest, Taxes, Depreciation, and Amortisation) is the most widely used measure of a company's operating profitability in corporate finance and M&A contexts. In Spain, as elsewhere, it serves as the basis for valuation multiples and financial covenant calculations, though its interpretation requires adjustments for Spanish accounting and tax specificities.

Transfer Pricing

Transfer prices are the prices set in transactions between related parties — companies within the same group, shareholders and their company, or directors and their company — which must be determined in accordance with the arm's length principle. Spanish tax law, aligned with OECD Guidelines, requires that these transactions be valued as if they had been carried out between independent parties and that the valuation method used be adequately documented.

Debt Restructuring

Debt restructuring is the process by which a company negotiates with its creditors to modify the terms of its financial obligations (maturity, interest rate, principal, or security) with the aim of restoring economic viability and avoiding insolvency. It can be carried out out-of-court or, if agreement cannot be reached with all creditors, through the pre-insolvency mechanisms provided for in the Spanish Insolvency Act.

Accelerated Depreciation in Spain (Amortización Fiscal Acelerada)

Accelerated depreciation (amortización fiscal acelerada) in Spain allows companies to deduct a higher proportion of an asset's cost in the early years of its useful life for Corporate Tax purposes, reducing taxable income sooner than straight-line accounting depreciation would permit. Spain offers both statutory accelerated tables and specific regimes for SMEs, newly hired personnel, and R&D assets.

EU AI Act

The EU Artificial Intelligence Act (Regulation EU 2024/1689) is the world's first comprehensive legal framework for artificial intelligence. It classifies AI systems by risk level, imposes obligations on developers, deployers, and importers, and establishes penalties of up to €35 million or 7% of global turnover for the most serious violations. It entered into force in August 2024 with phased compliance deadlines through 2027.

Annual Accounts (Cuentas Anuales)

Cuentas Anuales are the statutory annual financial statements that all Spanish companies must prepare, approve, and deposit at the Commercial Registry each year. They include the balance sheet, income statement, statement of changes in equity, cash flow statement (for larger companies), and notes.

FAQ

Frequently asked questions

Tax optimisation for an international manufacturing group involves analysing the value chain (where value is created: R&D, manufacturing, distribution), designing transfer pricing policies consistent with economic reality, leveraging the dividend and capital gain exemption under the Parent-Subsidiary Directive, and planning profit repatriation to minimise the global tax burden.
An industrial restructuring in Spain may involve negotiating a collective redundancy or temporary lay-off procedure (ERE or ERTE), applying the sector collective agreement, managing severance payments, engaging with employee representatives and notifying the labour authority. Proper planning and communication are key to minimising cost and legal risk.
Industrial companies with R&D activities can deduct between 25% and 42% of qualifying basic or applied research expenditure directly from their Corporate Tax liability, with the possibility of monetisation via cash-back for companies with insufficient tax liability. Technological innovation projects allow a 12% deduction. The key is correctly documenting the activities and projects that qualify as R&D.
Manufacturing companies importing raw materials must correctly manage the tariff classification of goods (TARIC code), the applicable customs regime, import VAT (recoverable in periodic declarations), tariff quotas and potential anti-dumping measures. Efficient management of these aspects can result in significant savings in procurement costs.
Selling a family-owned industrial company in Spain requires a professional business valuation, preparing the company for sale (vendor due diligence, account normalisation, contingency management), tax structuring for the seller (deferral through reinvestment in a new company, family business regime, IRPF/IS planning), buyer identification and negotiation of the purchase agreement.

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