Contact UsWe are considering holding our Spanish subsidiary through a Dutch limited partnership. This will be a so-called "closed Dutch CV", as anticipated by our US and Dutch tax counsels. The partnership will be checked to be treated as a corporation for US tax. Will Spain also regard it as a corporation? Or will Spain treat it as a look-through entity? Thank you in advance for your comments!
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Tax Professional Answers
Carlos Gabarro
As per the Spanish tax authorities criteria, generally a closed CV will be disregarded for Spanish tax purposes (hence, Spain will look-through the partnership into the US and apply, where required the US-Spain double tax treaty provisions). I would be pleased to review the partnership agreement or assist your Dutch legal counsel with this so that we can guaranty this is achieved. Please contact me at your convenience. Thanks!
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576 weeks ago