Your tax & financial partner across Europe.
Tax, corporate, and financial consulting for companies and groups operating in Spain, France, Luxembourg, and all of Europe. The advice that top firms give their best clients, with the direct partner access only a boutique can guarantee.
European OperationsFour areas where we make the difference
Complex operations made simple. Senior partner involvement from day one.
Holdings & Corporate Groups
Tax-optimized group architecture across Europe. Dividend exemption, ETVE, Luxembourg SOPARFI.
Company Formation in Spain
Express SL setup in 48h. Full legal & tax support from day one.
Company Restructuring
Tax-neutral mergers, spin-offs, and reorganizations under Art. 76 LIS.
Tax & Company Law
AEAT defense, corporate law, shareholders' agreements, and compliance.
Two areas, one total partner
Our Fiscal & Corporate area handles complex operations and structures. Our Financial area provides continuous monitoring, CFO services, and due diligence. Together, they make Aelea your complete financial partner in Europe.
International Tax Advisory
Transfer pricing, double tax treaties, BEPS, PE, DAC6, ATAD. Spain, France, Luxembourg & all of Europe.
Learn moreHoldings & Corporate Structures
Group design, ETVE, Luxembourg SARL-S, French SAS. Tax-optimized corporate architecture.
Learn moreM&A, Mergers & Acquisitions
Tax & legal due diligence, SPA review, tax indemnities, post-closing integration, carve-outs.
Learn moreTax Defense & Litigation
AEAT & DIAN inspections, TEAC appeals, historical regularization, disclosure models. Full defense.
Learn moreInternational Mobility
Beckham Law, tax residency transfers, France-Luxembourg cross-border workers, exit tax, EU Reg. 883/2004.
Learn moreCorporate Law
Shareholders' agreements, cross-border JVs, corporate governance, capital increases/reductions, exits.
Learn morePre-Insolvency & Restructuring
Law 16/2022, restructuring plans, creditor negotiations, technical support for liquidators.
Learn moreCross-Border Operations
Structuring transactions across European jurisdictions. Spain, France, Luxembourg, Benelux, DACH.
Learn moreWithout Aelea vs. With Aelea
Real situations that CFOs, financial directors, and European business owners face every day.
Holding structure designed without tax analysis — unmanaged double taxation risk.
Optimized group architecture across jurisdictions. Every entity has a tax-efficient purpose.
Tax inspection without a specialized advisor — unnecessary penalties and wasted time.
Full defense before AEAT. Appeals, regularization, and resolution by specialists who know the system inside out.
M&A deal without financial due diligence — post-closing surprises that destroy value.
Integrated financial, tax, and legal due diligence. One firm, one vision. No blind spots.
Tax residency change poorly executed — dual residency conflict between two countries.
Beckham Law, exit tax, cross-border workers — every move planned and documented.
European subsidiaries without financial monitoring — the board doesn't know what's happening in each country.
Monthly executive reports, consolidated KPIs, and early warnings across all jurisdictions.
Company in distress without pre-insolvency advice — avoidable bankruptcy proceedings.
Restructuring plans under Law 16/2022, creditor negotiation, and technical support for a controlled resolution.
Four steps to clarity
Every engagement follows a structured process that ensures precision, accountability, and measurable results for your business.
Diagnosis
Deep analysis of your tax, corporate, and financial situation. We identify risks, inefficiencies, and opportunities across every jurisdiction where you operate.
Strategy
Custom action plan design — structures, jurisdictions, execution timeline, and projected tax and financial impact tailored to your group.
Execution
Implementation with legal and tax support in each country. Coordination with trusted local advisors across all of Europe.
Monitoring
Continuous review of your structure and numbers. Periodic executive reports. Adaptation to regulatory changes or business shifts.
10 jurisdictions, one firm
We don't just advise from Spain. We operate across Europe with real presence, local knowledge, and trusted networks in every jurisdiction.
Spain
Domestic market. ETVE regime, Beckham Law, AEAT defense, pre-insolvency.
France
SAS structures, FR-LUX treaty, PFU flat tax, cross-border workers, URSSAF.
Luxembourg
European hub. Pillar 2, WHT on dividends, CSSF compliance, holding structures.
Belgium
Benelux hub. PE risk management, cross-border taxation, Benelux coordination.
Netherlands
BV holding structures, APA rulings, logistics and financial hub.
Germany
Europe's largest market. Betriebsstätte risk, GmbH structures.
Ireland
Tech & financial hub. 12.5% corporate tax, IP box regime.
Portugal
NHR/IFICI regime, international talent attraction, Iberian synergies.
Italy
Southern European operations, Italian-Spanish cross-border structures.
Colombia
DIAN, Art. 402, withholding agent, Spanish investment in Latin America.
The holding structure: protect, optimize, grow
A well-designed holding structure separates risk from wealth, optimizes tax flows between group companies, and facilitates succession. Here is a typical FEAC structure we implement for our clients.
Asset Protection
Separate operating risks from family wealth. If the operating company faces litigation, the holding's assets remain protected.
Tax Efficiency
Dividends between group companies can be 95% exempt under the participation exemption. Reinvest profits without immediate tax leakage.
Succession Planning
Transfer shares of the holding instead of individual assets. Benefit from the 95% reduction in inheritance tax for family businesses.
Centralized Management
Consolidate treasury, IP, real estate, and management services in the holding. Simplify group-wide decision making.
How we transformed a €2M company
A real case (anonymized) of a technology company with €2M revenue, 12 employees, and a French parent company. Real activity, real problems, real solutions.
Client Profile
Problems Found at Diagnosis
Full fiscal & financial audit
Corporate & tax optimization
Systems & processes
External CFO & compliance
Results After 12 Months
This could be your company. Every diagnosis starts with a conversation.
Get Your Free DiagnosisYour company's risk map
Every company operating in Spain faces regulatory risks. Without proper advisory, these risks accumulate silently until an inspection triggers severe consequences. This is a typical risk map we build for our clients during the initial diagnosis.
| Area | Risk | Probability | Impact | Potential Fine |
|---|---|---|---|---|
| Transfer Pricing | No documentation for intercompany transactions | High | Critical | €1,000–€20,000 per data set + tax adjustment |
| VAT Compliance | Late or incorrect VAT filings (Modelo 303) | High | High | 5–20% surcharge + 3.75% late interest |
| Permanent Establishment | Unregistered PE in Spain for foreign company | Medium | Critical | 50–150% of unpaid tax + criminal liability |
| Beneficial Ownership | No UBO register filing (Modelo 036/Titularidad Real) | Medium | High | €60,000–€1,000,000 (AML violations) |
| Annual Accounts | Failure to file annual accounts at Registro Mercantil | High | Medium | €1,200–€60,000 per year |
| Foreign Assets | Not declaring foreign assets (Modelo 720) | Medium | Critical | €5,000 per data item (min €10,000) |
| Social Security | Misclassifying employees as freelancers | High | High | €3,126–€10,000 per worker + back-contributions |
| Corporate Tax | Aggressive deductions without substance | Medium | High | 50–150% of unpaid tax |
No documentation for intercompany transactions
Late or incorrect VAT filings (Modelo 303)
Unregistered PE in Spain for foreign company
No UBO register filing (Modelo 036/Titularidad Real)
Failure to file annual accounts at Registro Mercantil
Not declaring foreign assets (Modelo 720)
Misclassifying employees as freelancers
Aggressive deductions without substance
Don't wait for an inspection to discover your risks. Get your free risk diagnosis today.
Request Risk AssessmentWhat happens when you don't comply
Spain's tax authority (AEAT) is one of the most aggressive in Europe. Non-compliance doesn't just mean fines— it can mean prison, asset seizure, and the end of your business. These are real penalties under Spanish law.
Tax Fraud (Delito Fiscal)
criminalDefrauded amount > €120,000
Fine of up to 6x the defrauded amount. Criminal record. Directors personally liable.
Very Serious Tax Infraction
very seriousUsing fraudulent means, concealment > €3,000
Public listing on AEAT's debtors list if debt > €600K. Loss of public contracts for 3 years.
Serious Tax Infraction
seriousUnpaid tax €3,000+ or >50% of correct amount
Automatic interest at 3.75%. Prohibition from obtaining subsidies. Potential embargo of assets.
Minor Tax Infraction
minorUnpaid tax < €3,000 and <50% of correct amount
Late payment surcharges: 5% (3 months), 10% (6 months), 15% (12 months), 20% (>12 months).
Social Security Fraud
criminalUnpaid contributions > €50,000
Directors personally liable. Company banned from public tenders. Back-payment of all contributions + 20% surcharge.
Anti-Money Laundering (AML)
very seriousFailure to comply with UBO/KYC obligations
Frozen bank accounts. Mandatory SAR filing. Potential criminal investigation. Public reprimand.
Directors are personally liable
Under Spanish law (Art. 43 LGT), company directors can be held personally liable for tax debts if they fail to exercise due diligence. This includes personal asset seizure, travel restrictions, and criminal prosecution. Ignorance is not a defense.
Prevention costs a fraction of the penalty
A proper compliance framework with Aelea Consulting costs less than a single minor infraction fine. We monitor, file, and defend — so you never face these consequences.
Protect Your Company NowThe Beckham Law: 24% flat tax in Spain
Spain's "Ley Beckham" (Régimen Especial de Trabajadores Desplazados, Art. 93 LIRPF) allows new tax residents to pay a flat 24% income tax rate instead of the progressive scale up to 47%. Originally designed for football players, it's now available to executives, entrepreneurs, and digital nomads.
Key Benefits
Requirements
The 2023 Startups Law expanded eligibility to entrepreneurs, highly qualified professionals, and digital nomads. Directors with >25% ownership can now also qualify.
How much can you save?
| Annual Income | Standard Regime | Beckham Law | Annual Savings |
|---|---|---|---|
| €60,000 | €15,600 (26%) | €14,400 (24%) | €1,200 |
| €100,000 | €30,200 (30.2%) | €24,000 (24%) | €6,200 |
| €150,000 | €52,600 (35.1%) | €36,000 (24%) | €16,600 |
| €250,000 | €99,600 (39.8%) | €60,000 (24%) | €39,600 |
| €500,000 | €217,100 (43.4%) | €120,000 (24%) | €97,100 |
* Approximate calculations based on 2025 rates. Includes state + regional surcharges for standard regime. Actual savings depend on personal circumstances.
Tax rates across jurisdictions
Compare the key tax rates across 11 jurisdictions where our clients operate. Understanding these differences is essential for structuring your international operations efficiently.
| Country | Corporate Tax | VAT / Sales Tax | Personal Income | Social Security | Dividend Tax | Capital Gains |
|---|---|---|---|---|---|---|
🇮🇪 Ireland | 12.5% | 23% | 20–40% | 11.05% | 25% | 33% |
🇨🇾 Cyprus | 12.5% | 19% | 0–35% | 8.3% | 0% | 0% (most) |
🇷🇴 Romania | 16% | 19% | 10% flat | ~35% | 8% | 10% |
🇱🇺 Luxembourg | 24.94% | 17% | 0–42% | ~25% | 15% | Exempt (SOPARFI) |
🇪🇸 SpainOUR BASE | 25% | 21% | 19–47% | ~36.5% | 19–26% | 19–26% |
🇵🇹 Portugal | 21% | 23% | 14.5–48% | ~34.75% | 28% | 28% |
🇫🇷 France | 25% | 20% | 0–45% | ~45% | 30% (PFU) | 30% (PFU) |
🇬🇧 United Kingdom | 25% | 20% | 20–45% | 13.8% | 8.75–39.35% | 10–20% |
🇲🇨 Monaco | 25%* | 20% (FR) | 0% | ~28% | 0% | 0% |
🇺🇸 USA | 21% | Sales tax 0–10% | 10–37% | 15.3% | 0–20% | 0–20% |
🇩🇴 Dominican Republic | 27% | 18% (ITBIS) | 0–25% | ~18% | 10% | 27% |
* Rates shown are standard/headline rates as of 2025. Actual rates may vary based on specific regimes, treaties, and individual circumstances.
Need help choosing the right jurisdiction? We analyze your specific case.
Request a Tax Comparison AnalysisUnderstanding taxes in Spain
Running a company in Spain comes with specific tax obligations. Here is a clear overview of the main taxes and filings every company must handle. We take care of all of them for you.
Corporate Tax (Impuesto de Sociedades)
All companies incorporated in Spain must file an annual corporate tax return. The standard rate is 25%, with reduced rates for new companies (15% for the first two profitable years).
VAT (IVA — Impuesto sobre el Valor Añadido)
Companies must charge, collect, and remit VAT on goods and services. The standard rate is 21%, with reduced rates of 10% and 4% for certain categories. Quarterly filings are mandatory.
Withholding Tax (Retenciones)
Companies must withhold income tax from employee salaries, professional fees, and certain rental payments, then remit these to the tax authorities quarterly.
Intra-Community Operations
Companies trading goods or services with other EU member states must file declarations of intra-community acquisitions and supplies.
Annual Accounts (Cuentas Anuales)
All Spanish companies must prepare and file annual accounts (balance sheet, P&L, notes) with the Commercial Registry within 6 months of their fiscal year-end.
SII — Immediate Supply of Information
Companies with turnover above €6M must report invoices electronically to AEAT within 4 days. Smaller companies may opt in voluntarily for faster VAT refunds.
Overwhelmed? Don't be. We handle all of this for you.
Let's TalkHow the payroll system works in Spain
Spain has a structured payroll system with mandatory social security contributions, income tax withholdings, and specific labor regulations. Here is how it works step by step.
The Payroll Process
Employment Contract
Every employee must have a written contract registered with the SEPE (public employment service). Contracts can be indefinite, temporary, or part-time, each with specific rules.
Gross Salary Calculation
The gross salary includes base pay, bonuses, overtime, and benefits in kind. Spain mandates 14 salary payments per year (12 monthly + 2 extra pays, usually in June and December).
Social Security Deductions
The employer contributes ~30% on top of gross salary. The employee contributes ~6.5% from their gross. Both are remitted monthly to the Social Security Treasury (TGSS).
IRPF Withholding
Income tax (IRPF) is withheld from the employee's gross salary based on progressive rates (19–47%). The rate depends on salary level, family situation, and contract type.
Net Salary Payment
After deducting Social Security and IRPF, the net salary is paid to the employee. A detailed payslip (nómina) must be provided showing all components and deductions.
Monthly & Quarterly Filings
Employers file Social Security contributions monthly (TC1/TC2) and IRPF withholdings quarterly (Modelo 111). An annual summary (Modelo 190) is due in January.
Example Payslip Breakdown
Employee earning €30,000 gross annual salary (14 payments)
Where we work

The boutique firm with European reach
Aelea Consulting is the boutique reference firm in fiscal, corporate, and financial consulting for companies and groups operating in Spain and Europe. With over 15 years of real experience in cross-border operations — from Madrid to Luxembourg, from Barcelona to Brussels — we offer the advice that major firms give to their best clients, with the direct partner access that only a boutique can guarantee.
We cover the full cycle: we structure the company, optimize its taxation, analyze its numbers, defend it before tax authorities, and accompany it in its sale or restructuring. In Spanish, English, French, and Dutch.
Our Journey
Founded in Barcelona
Started advising international companies on Spanish tax, corporate structures, and cross-border operations.
Madrid Headquarters
Opened our Madrid office at Calle Pensamiento 27 to serve the capital's growing international business ecosystem.
Malaga Office
Established presence in Malaga to support the booming tech and startup scene in southern Spain.
Luxembourg Operations
Expanded to Luxembourg with real operational presence for holding structures, SOPARFI, and cross-border advisory.
All of Europe
Full-service fiscal, corporate, and financial consulting across 10 European jurisdictions and Latin America.
Built for companies like yours
We work exclusively with companies and groups — from solo-founder startups to multi-entity holding structures. No private individuals, just focused B2B expertise across Europe.
Family Groups & Holdings
Multi-entity structures requiring consolidated reporting, succession planning, and group tax optimization across jurisdictions.
European Companies in Spain
German, French, Belgian, Dutch, and UK companies establishing or managing operations in Spain. We handle the local complexity.
Private Equity & Venture Capital
PE and VC funds needing due diligence, portfolio company support, and post-acquisition integration in Spain.
Startups & Scale-ups
Fast-growing companies that need agile financial management, investor-ready reporting, and fractional CFO services.
Multinationals & Subsidiaries
International groups with Spanish subsidiaries needing transfer pricing, intercompany management, and local compliance.
Companies in Distress
Businesses facing pre-insolvency, restructuring, or creditor negotiations under Spanish Law 16/2022.
Luxembourg Structures
SOPARFI, SARL-S, and holding companies needing coordinated ES-LUX advisory and ongoing compliance.
Spanish Entrepreneurs
Local entrepreneurs and SMEs seeking professional financial management, digital transformation, and strategic tax advice.
Real results for real companies
From Luxembourg holdings to AEAT inspections, from M&A due diligence to fractional CFO services — see how we deliver results across Europe.
Spanish Group Structures Holding in Luxembourg
A Spanish family group with subsidiaries in 3 countries needed a holding structure in Luxembourg to optimize dividend flows and consolidate European operations.
We designed the SOPARFI structure, constituted the SARL-S, analyzed the ES-LUX double tax treaty, and set up ongoing compliance with CSSF requirements.
Private Equity Fund Acquires Spanish Target
A PE fund needed integrated financial, tax, and legal due diligence on a Spanish target with subsidiaries in France and Portugal before closing a mid-market deal.
We delivered a combined financial DD (Quality of Earnings, working capital, net debt) and tax DD across all 3 jurisdictions. One firm, one vision, one report.
AEAT Inspection Defense for Tech Company
A fast-growing tech company received an AEAT inspection covering 3 fiscal years, with potential penalties exceeding €200K for transfer pricing and VAT issues.
Full defense before AEAT: documentation review, transfer pricing defense, TEAC appeal preparation, and direct negotiation with inspectors.
Fractional CFO for European Startup Group
A startup group with entities in Spain, France, and Germany needed consolidated financial visibility and a CFO-level interlocutor for their Series B investors.
We provided fractional CFO services: monthly consolidated P&L, cash flow forecasting, KPI dashboards, and direct communication with the investment committee.
What Our Clients Say
"Aelea structured our Luxembourg holding and managed the entire process. Their knowledge of both Spanish and Luxembourg tax law is exceptional. We now have a clean, compliant structure that works."
Powered by the best ERP tools
As certified partners of Odoo and Holded, we implement and customize ERP systems that automate your accounting, invoicing, and business processes. We bring the technology, you focus on growing your business.
ERP Implementation
We set up Odoo or Holded tailored to your business needs — from chart of accounts to automated invoicing workflows.
Process Automation
Automate bank reconciliations, expense categorization, VAT calculations, and recurring journal entries.
Real-Time Dashboards
Get instant visibility into your financials with custom dashboards showing P&L, cash flow, and KPIs in real time.
Ready to structure, optimize, and grow?
Request your free initial diagnosis. We'll analyze your tax, corporate, and financial situation across all your jurisdictions and propose a clear action plan.
Everything you need to know
Answers to the most common questions about company formation, taxes, payroll, and corporate structures in Spain.
A standard SL (Sociedad Limitada) can be incorporated in 2–4 weeks. This includes obtaining a NIF, drafting the articles of association, notarizing the deed, and registering with the Mercantile Registry. If you need an express incorporation, we can set up a PAE-based company in as little as 48 hours with a standard template.
The minimum share capital for a Sociedad Limitada (SL) is €3,000. It must be fully subscribed and paid at the time of incorporation. For a Sociedad Anónima (SA), the minimum is €60,000 with at least 25% paid at incorporation.
Yes. A branch (sucursal) is a permanent establishment of the foreign parent, not a separate legal entity. It's registered with the Mercantile Registry and taxed on Spanish-sourced income at 25%. However, a subsidiary (SL) often provides better liability protection and tax planning flexibility, especially for holding structures.
You qualify if you haven't been a Spanish tax resident in the previous 5 years, you relocate to Spain due to an employment contract or as a company director (with ≤25% ownership), or you're an entrepreneur or investor under the Startup Law. The regime allows you to pay a flat 24% on Spanish-sourced income up to €600,000 (instead of the progressive scale up to 47%) for 6 years.
Yes, since the 2023 Startup Law reform, entrepreneurs and digital nomads can also apply. If you're founding or directing an innovative startup in Spain and meet the residency requirements, you can benefit from the flat 24% rate. We handle the full application process, including Form 149 and coordination with the AEAT.
A holding company owns shares in one or more operating companies. In Spain, the participation exemption allows a holding to receive dividends and capital gains from subsidiaries tax-free (if it holds ≥5% for ≥1 year). This is ideal for groups with multiple business lines, international operations, or succession planning. We design structures like FEAC holding + operative + activity companies to optimize tax efficiency and protect assets.
Yes. Luxembourg offers SOPARFIs (holding companies) with access to an extensive double tax treaty network, EU Parent-Subsidiary Directive benefits, and no withholding tax on dividends to many jurisdictions. Our Luxembourg Desk designs and manages these structures, ensuring compliance with both Luxembourg CSSF requirements and Spanish CFC rules.
Every Spanish company must file: quarterly VAT returns (Modelo 303), monthly/quarterly withholding tax returns (Modelo 111 for payroll, 115 for rent), annual Corporate Tax return (Modelo 200, 25% standard rate), annual accounts with the Mercantile Registry, and informational returns like Modelo 347 (third-party transactions >€3,005.06) and Modelo 720 (foreign assets >€50,000). Missing any deadline triggers automatic penalties.
Late filing triggers automatic surcharges: 1% per month for the first 12 months (no penalty if voluntary), then 15% + late interest after 12 months. If the AEAT issues a formal requirement before you file, penalties range from 50% to 150% of the tax due, depending on severity. For repeat offenders, criminal prosecution is possible for fraud exceeding €120,000 per fiscal year.
Spanish payroll involves: gross salary calculation, IRPF withholding (progressive, based on personal circumstances), Social Security contributions (employer ~30%, employee ~6.5%), and net pay. Employers must register with the Social Security Treasury, issue monthly payslips (nóminas), and file monthly contribution reports (TC1/TC2). There are 12 monthly payments plus typically 2 extra payments (June and December).
The employer's Social Security contribution is approximately 30–31% on top of gross salary. This includes: common contingencies (23.6%), unemployment (5.5–6.7%), FOGASA (0.2%), and professional training (0.6%). For a €30,000 gross salary, the total employer cost is approximately €39,000–€39,300. We optimize structures using legal benefits like reduced rates for new hires, R&D deductions, and international mobility schemes.
A fractional (external) CFO provides senior financial leadership without the cost of a full-time hire. We deliver: monthly consolidated P&L and cash flow reporting, KPI dashboards, budget vs. actual analysis, bank and investor communication, financial due diligence support, and board-ready reporting. Ideal for startups preparing for Series A/B, groups needing consolidated reporting across jurisdictions, or companies in restructuring.
Our external CFO service is included in the Full CFO plan at €1,400/month for groups of up to 3 companies. This covers monthly closings, consolidated reporting, cash flow management, KPI dashboards, and direct communication with your investors or board. For larger groups or more complex structures, we provide a custom quote based on the number of entities and jurisdictions involved.
Don't see your question here?
Ask Us DirectlyRequest your free diagnosis
Tell us about your company and your situation. We'll analyze it and propose a clear action plan — no commitment, no cost for the initial consultation.