International tax advice for investment between the U.S. and Spain
Consider the cross-border tax questions alongside the investment structure, business activity and transaction.
Discuss your plans
Put the facts before the structure
Describe the investor, the proposed ownership, the planned activity and the countries involved. A useful tax conversation starts with those facts rather than an assumed result or a headline rate.
Review the cross-border questions
Gowper’s published international taxation practice addresses planning, compliance and the interpretation of tax treaties. Ask how those areas relate to the particular investment you are considering.
Keep the transaction and tax work connected
Changes to the purchaser, financing or operating arrangements may change the questions to be reviewed. Discuss the tax scope while developing the corporate or property documents, rather than treating it as a separate final step.
Areas to discuss
- International tax planning for business activity
- Cross-border compliance questions
- Treaty interpretation within the agreed scope
- Tax considerations in investment structures
A useful starting brief.
These questions help frame a first conversation. The documents and work required will depend on your project.
- Who will own the asset or Spanish entity?
- Which countries are connected to the investor and business?
- How will the investment be financed?
- What existing advisers and reporting arrangements are involved?
Does the U.S.–Spain tax treaty automatically eliminate every tax obligation?
This page makes no assumption about your treaty eligibility or tax result. The facts and relevant treaty provisions need to be assessed for the particular case.
Where can I find the treaty documents?
The IRS publishes the Spain treaty and protocol documents. The official source is linked below; it is a starting point for the review, not a substitute for advice.
The IRS lists the Income Tax Treaty
and Protocol
on its Spain treaty documents page.
Company formation
Corporate legal advice for U.S. founders and businesses planning to establish a company or commercial presence in Spain.
02Real estate investment
A legal perspective on your Spanish property investment, from the intended use of the asset to the terms of the acquisition.
03Business acquisitions & M&A
Legal due diligence, negotiation and transaction support for U.S. investors considering the acquisition of a Spanish business.
Discuss your u.s.–spain international taxation plans.
Tell us about your proposed investment and the legal questions you want to resolve.