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E.T.V.E. the Spanish Holding Company

The perfect bridge connecting Latin America to Europe and US

At CPA we are the ETVE expert and we offer you the broadest tailor-made solution to make sure every aspect of your business works smoothly.

Spain is the place of choice to locate a Holding Company.


Spain has the most extensive network of Double Taxation tax treaties, with all major economies in the world.

Thanks to Spain’s membership in European Union, ETVE are protected by 2 EU directives, the Parent-Subsidiary Directive and the Merger Directive.

Spanish ETVE regime has passed the “harmful tax competition test” of EU.

Not included in the Black List of Code of Conduct of the EU.

The E.T.V.E. regime at a glance

The ETVE is a regular entity, in the form of a corporation or a limited liability company. Therefore subject to normal corporate tax. With the sole distinction of providing an exemption for dividends and capital gains deriving from subsidiaries. Under ETVE regime, non-resident shareholders are not taxed in Spain. ETVE’s income coming from subsidiaries can also be repatriated to the shareholder’s country without being liable for Spanish tax or any withholding.

Main Advantages

Total exemption in Spain for dividends and capital gains coming from the subsidiaries. Interests are fully deductible.

Corporate Purpose and Substance

The ETVE regime the company has enough resources to ensure the proper administration of the investments. Majority of directors must be in Spain. On the other side, there is no limitation to the business activity the holding company can carry out.


5% or more of direct or indirect participation in subsidiary. Held for at least 12 months. The subsidiary must be in a country that has signed a treaty for exchange of information or has similar taxation to Spain. Income earned outside of Spain must be at least 85% active income for the subsidiary. Real estate, finance, credit qualify given sufficient operational substance. Shareholders can not be resident in tax heaven.

The four criterias met by the E.T.V.E


Incoming dividends remitted by the subsidiary must be exempted from withholding tax


Dividends received must be exempt from corporate income tax in the holding company’s jurisdiction.


Profits realized on the sale of subsidiaries’ shares must be exempt from tax in the holding company’s jurisdiction.


Dividends paid by the holding company to the ultimate parent company must be exempt from withholding taxation in the holding company’s jurisdiction.

For more information on the E.T.V.E. regime and on how we can help you, please contact us.