The Spanish Tax Regime for Foreign-Securities Holding Companies (Etve Regime)

The Spanish tax regime for Foreign-Securities Holding Companies, known in Spain as «entidades de tenencia de valores extranjeros» («ETVE») is considered as one of the most competitive holding regimes in the European Union.
1. Definition and main benefits of this Regime

Companies under the ETVE Regime are Spanish resident companies whose corporate purpose includes «the management and administration of shareholdings in non-resident entities using the appropriate organization of material and personal resources». The tax regime applicable to these entities is governed by articles 116-119 of the Spanish Consolidated Text of the Corporate Income Tax Act (Texto Refundido de la Ley del Impuesto sobre Sociedades), as approved by Royal Legislative Decree (Delegated Act) 4/2004, of 5 March («TRLIS»)…