Services
We advise on the full spectrum of international tax and structuring challenges — from inception to execution.
European holding structures & spanish ETVE
For Latin American investors, entrepreneurs, and investment platforms seeking to channel capital into international operations, the design of an efficient holding structure is not a technical formality — it is a strategic decision with long-term consequences.
Candal Advisors Group has developed deep expertise in European holding architectures, with particular focus on the Spanish ETVE (Entidad de Tenencia de Valores Extranjeros) regime — one of the most advantageous frameworks available for Latin American investors holding stakes in non-resident operating companies.
The ETVE regime offers significant advantages for qualifying structures: exemption from Spanish tax on dividends and capital gains derived from qualifying foreign subsidiaries, and favorable treatment of distributions to non-resident shareholders. When properly structured, it provides a tax-efficient, legally robust, and commercially credible holding platform for cross-border investment.
Our services in this area include:
- Feasibility analysis and regime qualification assessment.
- Corporate design and incorporation of Spanish holding entities.
- Governance structuring and substance requirements.
- Ongoing compliance and annual reporting.
- Restructuring of existing holding arrangements.
- Coordination with local counsel across relevant jurisdictions.
International tax strategy & cross-border structuring
Cross-border operations create complexity at every level — from entity structure and intercompany transactions to dividend flows, financing arrangements, and exit planning. Managing that complexity requires both technical precision and strategic judgment.
We advise families, entrepreneurs, investment platforms, and funds on the design and implementation of tax-efficient cross-border structures — across the Spain–United States–Latin America corridor and beyond.
Our advisory in this area covers:
- Multi-jurisdictional tax planning and structure design.
- Cross-border mergers, acquisitions, and reorganizations.
- Holding company and intermediate structure optimization.
- Inbound and outbound investment structuring (US, Spain, Latin America).
- Tax treaty analysis and application.
- Permanent establishment risk assessment and management.
- Exit planning and liquidation structuring.
Family office & multigenerational wealth advisory
For families managing significant wealth across multiple jurisdictions, tax planning is inseparable from broader questions of governance, succession, and long-term preservation. The decisions made today — about structure, jurisdiction, and beneficial ownership — will shape the family’s financial position for generations.
We provide integrated advisory to global families and family offices, combining international tax expertise with a deep understanding of the structural and relational dimensions of multigenerational wealth.
Our services include:
- Cross-border wealth structuring and holding architecture.
- Trust and foundation planning across relevant jurisdictions.
- Succession planning with tax optimization.
- Family governance structures with international tax efficiency.
- Asset protection planning across multiple jurisdictions.
- Coordination of tax planning with estate and succession objectives.
- Ongoing advisory as family situations and international frameworks evolve.
Transfer pricing
Transfer pricing is one of the most technically demanding and commercially consequential areas of international tax — and one where the quality of documentation and the defensibility of the methodology can determine the outcome of an audit years later.
We advise international groups and investment platforms on the design, documentation, and defense of intercompany pricing policies that are both tax-efficient and fully compliant with OECD guidelines and local regulations.
Our transfer pricing services include:
- Policy design and intercompany agreement structuring.
- Benchmarking analysis and comparability studies.
- Local File documentation (OECD BEPS compliant).
- Transfer pricing risk assessments for existing structures.
Cross-border tax compliance
International tax compliance for entities with obligations in multiple jurisdictions requires both technical accuracy and a clear understanding of how different regimes interact. An error or omission in one jurisdiction can have consequences in others.
We coordinate international tax compliance for clients with obligations across the United States, Spain, Venezuela, and other European or Latin American jurisdictions — working alongside the client’s existing tax advisors, or bringing in trusted professionals from our network of specialist firms, to ensure accuracy, timeliness, and consistency across all filings.
Investment platform & fund tax advisory
Investment platforms, private equity vehicles, and funds operating across borders face a distinct set of tax challenges — from entity selection and investor structuring to carried interest treatment, withholding tax management, and exit planning across multiple jurisdictions.
We provide specialized tax advisory to investment platforms and funds requiring cross-border structuring, European holding architecture, and multi-jurisdictional compliance — with particular expertise in structures serving Latin American investors and holding assets in Spain, the United States, and the broader region.
Our services for investment platforms include:
- Fund structure design with tax efficiency across investor and asset jurisdictions.
- European holding architecture for cross-border investment vehicles.
- Investor tax analysis and structuring (including HNWI and family office investors).
- Withholding tax planning and treaty optimization.
- Carried interest and management fee structuring.
- Exit and liquidation tax planning.
