Case study · Tax
Structuring a private equity investment in Mallorca real estate
We designed the Spanish tax structure for an overseas investment fund acquiring and developing a high-value real estate asset in Mallorca.
The investment combined acquisition, development, external financing and a future disposal, with investors and decision-makers outside Spain.
Our role was to make the Spanish structure efficient and workable across the full investment cycle.
The challenge
- Corporation tax, VAT and transfer-tax interactions.
- Permanent-establishment and withholding-tax exposure.
- Debt funding and cash repatriation across borders.
- A structure capable of supporting development and exit.
Our approach
Technical precision, focused on the client.
Model the lifecycle
We modelled acquisition, construction, operation, refinancing and exit rather than optimising one transaction in isolation.
Coordinate the jurisdictions
Spanish advice was reconciled with fund and investor counsel so that local efficiency did not create leakage elsewhere.
Implementation discipline
Governance, invoices, financing documents and filings were incorporated into a practical closing and post-closing plan.
The outcome
The fund adopted a structure that supported the commercial timetable and gave its investment committee a clear view of Spanish taxes at each stage.
The implementation plan allocated responsibilities among the fund, administrators and local project team, reducing the risk of a technically sound structure failing in operation.
Real estate tax structuring works when acquisition, development, financing and exit are designed as one investment cycle.
The Lullius approach
