Focused area

Spanish taxation of foreign trusts and fiduciary structures

Understanding the document is not enough: the Spanish analysis turns on control, beneficial rights and what happens in practice.

Spanish taxation of trusts, foundations and foreign structures depends on their terms and real operation, not on the label used abroad.

We analyse rights, control, contributions, distributions and the residence of everyone involved, together with reporting duties and the consistency of previous filings.

Lullius coordinates trustees, protectors and foreign advisers so the structure can be translated into facts relevant under Spanish tax law and future decisions can be anticipated.

Focused support

Analysing fiduciary structures

Trust deed review

We examine the deed, letters of wishes, amendments and related agreements to identify powers, rights and events relevant to the Spanish analysis.

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Form, control and reality

Analytical framework

Treatment follows the facts. We examine who contributes, controls, administers and may benefit from the assets. Those facts are more informative in Spain than a foreign legal label.
Distribution records matter. Before a distribution, we review its source, approval, accounting and prior treatment. Resolutions and accounts should explain the transaction consistently.
Genuine cross-border coordination. Foreign counsel explains the structure at source and Lullius determines its Spanish treatment. Both analyses must rely on the same facts and documents.
A protocol for future decisions. We identify events requiring review and records that should be retained, allowing beneficiaries and administrators to seek advice before a material step is taken.