Emigration to Spain: exit tax cut from €198,000 to €34,000

BV ownerEmigration to Spain

Tax · Exit tax

€34,000Exit tax
€164,000Saved
NoneDouble taxation

Initial situation: exit tax threatened to derail the emigration

A Belgian entrepreneur moved his tax residence to Spain. His company held substantial reserves and latent capital gains on shareholdings. The Belgian exit tax threatened to derail his emigration plans. He was also unfamiliar with the Spanish wealth tax and the double tax treaty.

€198,000Exit tax at stake
Latent capital gainsAsset position
Double taxationRisk

Approach: the emigration structured in phases

Step 1
Situation mapped: timing, asset mix and exit tax per asset class analysed.
Step 2
Phasing set: certain dividend distributions and realisations carried out before the emigration date.
Step 3
Unwinding in Belgium: the full tax unwinding in Belgium supported.
Step 4
Registration in Spain: registration as a Spanish tax resident arranged.

Outcome: exit tax reduced to €34,000

Correct phasing brought the exit tax down from €198,000 to €34,000. The entrepreneur is registered as a Spanish tax resident, his Belgian obligations are closed and there is no risk of double taxation.