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Abstract
The Spanish holding (also known as ETVE) is not an offshore regime. An ETVE is an entity resident in Spain for tax purposes and subject to tax on its worldwide income. It benefits from an exemption on inbound dividends and capital gains obtained or realized when certain requirements are met. It also entitles its shareholders to receive dividends and realize capital gains on a tax-free basis, subject to certain requirements. The ETVE regime is recognized and stable as it does not appear in the Organization for Economic Cooperation and Development list of tax havens, any country's black list, or in the European Code of Conduct. So an ETVE is an advantageous and reliable European-holding vehicle.