Dividends from a Luxembourg or Dutch company are taxed in Spain at 19% to 30% in 2026, with the 15% foreign withholding credited. Spain's TFI rule taxes the income of controlled foreign companies paying less than about 18.75%, and a company managed from Spain becomes Spanish. Shares are declared on Modelo 720, count for wealth tax and can trigger exit tax. Under the Beckham regime foreign dividends are generally outside Spanish tax.
How Spain looks at your foreign company
Spain taxes its residents on their worldwide income. Owning shares in a Luxembourg or Dutch company does not change that: the dividends you receive are taxed in your Spanish return, in the savings base, at 19% to 30%. The withholding tax deducted in Luxembourg or the Netherlands, usually 15%, is credited, so in most cases you pay the Spanish rate in total.
The bigger questions are about the company itself. If you run it from your home in Madrid or Barcelona, Spain can say the company is effectively managed in Spain and therefore Spanish for tax. If the company pays very little tax and you control it, the Spanish CFC rule (transparencia fiscal internacional) can tax its profit in your hands every year, whether or not you take a dividend.
Neither risk applies to a Luxembourg or Dutch company that has real directors, real decisions and ordinary taxation. Both apply quickly to a company that exists mainly on paper.
Why Spanish residents set up in Luxembourg and the Netherlands
Spanish founders, investors and new arrivals use Luxembourg and Dutch companies for international holdings, funds, IP and as the EU hub of a non-Spanish business. Spain, however, taxes its residents on worldwide income, has a strict CFC rule, an aggressive view of where companies are managed and its own reporting regime. A foreign company works for a Spanish resident only when it would also convince the Agencia Tributaria.
19% to 30%
Savings base in 2026, with credit for the 15% foreign withholding.
Below about 18.75%
50% control and low tax bring income back to Spain.
Effective management
A company run from Spain is Spanish.
Modelo 720 and 721
Foreign shares, accounts and crypto above EUR 50,000.
The Spanish rules that follow the company
- TFI (international tax transparency). Spanish control of 50% or more, foreign tax below 75% of Spanish corporate tax, and passive income, or all income without substance: taxed in Spain each year. EU companies escape with valid business reasons and real activity.
- Place of effective management. Board decisions taken in Spain make the company Spanish-resident.
- Wealth and solidarity tax. Shares in a passive foreign holding count in full; the family-business exemption needs real activity, at least 15% and a salary that is most of your income.
- Exit tax. Leaving Spain with shares worth more than EUR 4 million, or more than 25% of a company worth over EUR 1 million, triggers tax on unrealised gains after 10 years of residence.
- Beckham regime. Six years taxed as a non-resident: foreign dividends and gains generally outside Spanish tax.
For a Spanish resident, a Luxembourg company is not a tax rate. It is a second set of board minutes that must be true.
Beckham regime, wealth tax and leaving Spain
New arrivals under the Beckham regime are taxed for six years essentially as non-residents: employment income at 24% up to EUR 600,000, and most foreign-source income outside Spanish tax. For them, a Luxembourg or Dutch holding can receive and accumulate income without Spanish tax, provided the company is genuinely managed outside Spain.
Ordinary residents should also think about wealth tax and the solidarity tax on large fortunes. Shares in a foreign company count at their value; the family business exemption can apply only to active companies where you work and earn most of your income. A passive holding does not qualify.
A Spanish resident takes a EUR 100,000 dividend from a Luxembourg holding. Luxembourg withholds EUR 15,000; Spain calculates EUR 21,880 of savings tax and credits the EUR 15,000, so EUR 6,880 is paid in Spain. Under the Beckham regime, the Spanish part would generally fall away.
Check your Spanish position
Indicative 2026 savings base rates; the foreign withholding is credited.
Spanish resident with a Luxembourg or Dutch company
Enter the dividend and answer five questions. You get the Spanish tax and the risk points.
On dividends in Spain.
With 50% control.
Or the company is Spanish.
Foreign dividends outside Spain.
Spanish residents with a Luxembourg or Dutch company: frequent questions
How are Luxembourg or Dutch dividends taxed for a Spanish resident?
They go into the savings base at 19% to 30% in 2026. The 15% Luxembourg or Dutch withholding tax is credited against the Spanish tax, so the total is the Spanish rate.
Does the Spanish CFC rule (TFI) apply to a Luxembourg company?
Only if a Spanish resident controls 50% or more and the company pays less than 75% of what Spanish corporate tax would be, that is below about 18.75%. A normally taxed Luxembourg or Dutch company is outside; an IP box or SPF can fall inside unless the EU business-reasons exception applies.
Can Spain treat my Luxembourg company as Spanish?
Yes. If its effective management is in Spain, because you run it from Spain, it is a Spanish tax resident and pays Spanish corporate tax.
Do I have to declare the company on Modelo 720?
Yes, shares in foreign companies are declared on Modelo 720 when the total of that asset category exceeds EUR 50,000; foreign bank accounts and securities follow the same rule.
What about the Beckham regime?
Under the Beckham regime only Spanish-source income is taxed, at 24% on employment income up to EUR 600,000. Dividends from a foreign company are generally not taxed in Spain during those six years.