Tax planning that protects what you have built

Taxation is a decisive factor in the profitability and competitiveness of any business. At BMC, our tax advisory team combines deep expertise in Spanish and international tax law with a strategic business perspective to design solutions that optimise your tax position within the legal framework.

We advise domestic and international companies on tax planning, corporate transaction taxation, transfer pricing, regulatory compliance and the special tax regimes available across Spanish territories. Our priority is that every tax decision is taken with legal certainty and a long-term perspective.

With a track record spanning over two decades, we have helped hundreds of companies navigate an increasingly complex and evolving tax environment, anticipating risks and capturing opportunities that others overlook — from accessing the ZEC regime in the Canary Islands to mounting a robust defence against AEAT inspections.

Comprehensive tax advisory: from day-to-day compliance to complex transactions

Business taxation cannot be managed in silos. A corporate acquisition simultaneously opens fronts in Corporate Income Tax, related-party transactions, VAT and property transfer tax. An international expansion activates transfer pricing obligations, permanent establishment risk, Form 720 filing requirements and potential double taxation.

Our working model integrates all these dimensions under a single senior point of contact who coordinates specialists in each area. That is the difference from a traditional tax advisory practice: the ability to anticipate the cross-cutting implications of each decision before they materialise in a supplementary assessment or an intervention by the Tax Inspectorate.

Tax practice areas

Our capabilities cover the full spectrum of business and personal taxation:

• Tax planning: Design of fiscally efficient structures for groups, corporate reorganisations, mergers and demergers with tax neutrality. Our tax planning guide 2026 sets out the priority levers for the current financial year.
• Corporate Income Tax: Computation and review of corporate income tax, utilisation of R&D&I deductions, offsetting of tax loss carryforwards, and application of the tax consolidation regime where applicable.
• VAT and indirect taxes: Management of VAT in complex transactions — intra-Community supplies, exports, triangular transactions, SII, Form 303, Form 347 — and VAT fiscal representation for non-residents.
• International taxation: Advisory to groups with cross-border activity. Application of double tax treaties, dividend and interest withholdings, and structures leveraging the Parent-Subsidiary Directive. For non-residents, comprehensive IRNR and wealth tax advisory.
• Transfer pricing: Preparation of mandatory documentation (masterfile + local file), comparability analyses, sector margin benchmarks and technical defence before the AEAT on related-party transactions.
• Ley Beckham and inpatriates: Eligibility assessment, regime application, maintenance throughout the 6-year applicable period and management of the post-regime transition. For residency changes, see the guide to non-resident tax filing in Spain.
• Zona Especial Canaria (ZEC): End-to-end advisory for businesses wishing to establish under the ZEC regime with a 4% corporate rate. The complete ZEC guide for 2026 defines the current opportunity window before the December 2026 deadline.
• Cryptocurrency taxation: Declaration of crypto assets, Form 721, staking and DeFi taxation, and compliance with the DAC8 automatic exchange regulations.
• Inheritance and wealth tax: Wealth planning, application of the family business exemption, inter-regional Inheritance Tax and succession anticipation strategies.
• Trade and customs: Tariff classification, special customs regimes and Intrastat for companies with intra-Community trade flows.
• AEAT inspection defence: Procedural strategy, pleadings, appeals, administrative review proceedings and judicial defence in the contentious-administrative jurisdiction against potential tax penalties.

Tax compliance and fiscal calendar

Compliance with formal obligations is the first line of defence against the tax authorities. We manage the complete fiscal calendar for our clients: Corporate Income Tax, VAT, withholdings, Form 720, Form 232 on related-party transactions, Form 347, Form 200, SII, and sector-specific forms as applicable.

The tax compliance service guarantees formal monthly, quarterly and annual compliance with full traceability. Staying ahead of deadlines prevents penalties and eliminates cashflow surprises at each tax instalment date.

Territorial tax advisory

Spain has a heterogeneous tax landscape. The foral territories (the Basque Country and Navarre) have their own tax codes, the Canary Islands operate under ZEC and REF, and the autonomous communities exercise legislative competence over inheritance, gift and wealth taxes. We have offices and collaborators in the principal locations:

• Tax advisory in Madrid for companies with headquarters and complex parent-subsidiary structures.
• Tax advisory in Málaga and Marbella for international wealth, the Ley Beckham regime and high-net-worth fiscal residency.
• Tax advisory in Murcia for the Levante business community, with specialisation in agri-industrial and real estate sectors.
• Tax advisory in Las Palmas for companies operating under the ZEC and entities covered by the Canary Islands Economic and Fiscal Regime.

Relevant case studies

• International group tax optimisation: holding structure redesign reducing the effective tax rate from 28% to 19%.
• International group tax restructuring: partial demerger with tax neutrality and capital gains saving of €6.4M.
• Ley Beckham regime for technology executive: cumulative tax saving of €420,000 over the 6-year period.
• ZEC Canary Islands holding establishment: operational migration and regime accession with estimated annual saving of €2.1M.

When to contact the tax team

We recommend contacting our tax advisory team when:

• You are planning a corporate transaction — acquisition, merger, demerger — with complex tax implications.
• You are expanding activity to another country and need to validate international tax fit and the existence of a permanent establishment.
• You receive a notification from the AEAT: an information request, limited verification or the opening of a full inspection.
• You are a foreign executive relocating to Spain and considering the inpatriate regime.
• Your technology or internationally active company is evaluating establishing a presence under the ZEC regime before the current fiscal window closes.
• You need VAT fiscal representation for non-residents for operations in Spain without a local entity.
• You are managing an estate or family succession with inter-regional tax implications.

A no-commitment tax consultation is the first step to assessing risks and opportunities. The cost of preventive tax advisory is always lower than that of an AEAT inspection defence on facts already crystallised.