Santander, AXA Appeal EU Challenge To Spanish Tax Break

By Jack Schickler Law360 (January 31, 2019, 1:45 PM EST) — Santander Bank and insurance company AXA are appealing a November European Union court ruling that deemed a Spanish corporate tax break to be a breach of the bloc’s competition laws, according to documents published by the court.

The cases, filed Jan. 25 and appearing on the court’s website Wednesday, were the latest stage in a decadelong saga that has led the bloc to redefine the circumstances in which tax advantages are deemed to unfairly favor a particular sector and constitute unlawful state aid. The EU’s general court last year ruled against the financial institutions, as well as Deutsche Telekom and the multinational retailer World Duty Free Group, when it held that a Spanish “goodwill” corporate tax reduction for the takeover of foreign companies breached EU law.

The November judgment applied a 2016 doctrine from the more senior European Court of Justice, which said a tax break could be “selective,” hence illegal, even though any company couldin principle, have benefited by making different commercial decisions.

In 2009 and 2011, the European Commission ruled against Spain after EU lawmakers in 2005 had asked whether the tax break, intended to reflect the intangible value of a company’s reputation, effectively subsidized takeovers of mobile phone business O2, energy company Scottish Power and the semiprivatized French freeway network.

James McSwiggan – CIC’s Specialist in Mergers & Transactions

The cases are Sigma Alimentos Exterior v. Commission, World Duty Free Group v. Commission, Banco Santander v. Commission, Banco Santander and Santusa v. Commission, AXA Mediterranean v. Commission and Prosegur Compañía de Seguridad v. Commission, case numbers C-50/19, C-51/19, C-53/19, C-54/19 and C-55/19, in the Court of Justice of the European Union.

–Editing by Neil Cohen.

London Tel:  +44 207 129 7086

Spain Tel:  +34 910 085 807

ZEC Tax Advisory Tenerife & Gran Canaria Canary Islands

Artificial intelligence ‘made in Spain’ to compete with Amazon Alexa

Intellectual Property & EU Tax Incentives in Spain & Canary islands

Nacho Palou ,

Digital Economy

14 Dec 2018 16: 41h.

  • A Spanish company has created a virtual assistant with AI that anticipates the needs of the user. 
  • His application was the first to communicate in conversational language in Spanish. 
  • It has received a great update and can be downloaded and used for free. 
  • It is designed to be integrated into any device. 

Founded in Bilbao in 2012, the Sherpa company aims to develop the next generation of digital assistants by applying artificial intelligence to anticipate and predict what information and actions the user needs or wants depending on the time and place and different conditions.

Sherpa Assistant App , the incarnation as an app for Android phones, was one of the first digital assistants with the ability to communicate through conversational or natural language in Spanish, and is the number one app of its category in the Spanish-speaking market. Recently the Sherpa app has evolved and can be  downloaded and used for free .

The company, based in Bilbao, and offices in Silicon Valley, has recently announced a lucrative agreement with Porsche to incorporate the Sherpa Platform services. The business version of the Sherpa platform consists of two products: Sherpa AI Conversational OS and Sherpa AI Predictive and Recommending engine.

The Sherpa AI Conversational OS platform presented today is designed to enable Sherpa conversational engine integration “on any device or product, from speakers to TVs to household appliances,” Sherpa explains.

The second component of the Sherpa Platform, the Sherpa AI Predictive and Recommending Engine, makes available to companies and developers the Sherpa predictive technology for its integration into different products as an intelligent interface that is capable of anticipating the needs of the user without having to that the user interacts directly with the system.

In this way, they  explain from Sherpa , “the user will have at their disposal an assistant able to select news or emails that require their attention.” Furthermore, they can control the home heating or play multimedia content on the television and control other devices and connected devices.

Canary Islands ZEC Zone Tax Incentive

According to  Xabi Uribe-Etxebarria , founder and CEO of Sherpa, Sherpa’s predictive capacity is about 100,000 parameters for each user, which places his technology “at the head of artificial intelligence worldwide.”

Find out how Capital Investment Consultants can identify and position your IP, support you to secure capital investment, optimise net profits and accelerate your equity value.

London Tel:  +44 207 129 7086

Spain Tel:  +34 910 085 807

Canary Islands are UK Companies Solution for No Deal Brexit!

Where to place your business in the EU after Brexit

In light of the Brexit uncertainty, regardless of one’s personal stance, EU subsidiary corporate structures have become a popular provision for many clients, with Spain’s Canary Islands emerging as the front runner.

Uncertainty over the UK’s post-brexit relationship with the EU has caused concern for business owners and investors alike, however, many business owners are also realising the full extent of the opportunities enabled by having a Corporate Structure in the European Union.

Canary Islands ZEC Zone Tax Incentive

The Canary Islands offers companies the opportunity to provide continuity of service to clients whilst accessing the EU’s most advantageous Onshore Tax Incentives.

The Canary Islands Tax Incentives, are part of a permanent “Ultra Peripheral Regions” status unlike those of Cyprus, Malta, and other EU locations, they provide a more “Secure and Stable” longer-term option. Specifically, both Investors and Business Owners alike can position their businesses in the Canary Islands enjoying the following;

  • Corporate Tax Rates as low as 2.5 – 4% (The Lowest in Europe)
  • Invoice EU clients without VAT
  • Trade in Euro’s without need for currency transfers
  • Freedom of movement of funds due to onshore status and bi-lateral agreements
  • Exemption from withholding tax
  • No double taxation due to bi-lateral agreements
  • Exemptions on Stamp Duty and Transfer Tax

The powerful side effects of the above mentioned benefits can be, accelerated commercial growth, higher company valuations, optimized net profits, maximum equity retention when entering VC or PE investment rounds. 

The Canaries offers an opulent life work environment, educated multi-lingual workforce, world class communications infrastructure, more than 1000 direct weeklyflights to EU cities (460 of which are to the UK) plus business owners and companies enjoy the EU’s legal, economic and financial stability.

To discover how Capital Investment Consultants can support your business contact:

Tel: +34 674 136 977 

The EU’s Best Kept Business Secret

Europe’s Biggest Business Secret,

Since the year 2000, this European location has attracted international businesses like Kinross, Rolls Royce Marine and AtoS, in addition to fast-growing digital businesses with global ambitions.

This location has, the same time zone as the UK, Euro currency, Spanish & English is widely spoken, and boasts daily direct flight to many EU cities.

It has a young, educated, bilingual workforce, yet the biggest secret is… It boasts the Lowest “Onshore” Corporate Tax Rate in Europe, just 4%!!!

The location? The Canary Islands…

The Canaries are hugely popular with Nomads, Digital Entrepreneurs and becoming home to more corporates, particularly those interested in the African market.

Prolific for branding themselves as a year-round paradise for tourists, The Canaries have seen more than 400 companies register for their special tax incentive since the year 2000.

Basing themselves away from the tourist culture, international companies tend to reside in the Cities of Las Palmas de Gran Canaria and Santa Cruz de Tenerife.

If you’re asking yourself why you haven’t heard of these tax incentives before, it’s largely because they’re legally backed “Onshore EU Tax Incentives”!

Unlike seedy offshore tax havens, that so often grab the headlines, the Canary Islands offers, political, financial, and social stability combined with world class communications infrastructure and logistical connectivity.

British Airways in-flight Magazine recently spoke with CIC Founder, Christopher Pennington, to discover “why fast-growing companies are gravitating to the islands”?

Canary Islands ZEC Zone Tax Incentives

“CIC has helped small, 5 people entrepreneurial businesses, to 50+ people companies, establish a base for international expansion in the Canaries. Business Owners benefit from CIC’s unique understanding of how to best apply credible EU Tax Incentives like the ZEC (Zona Especial Canarias).

One huge draw being, companies remain onshore, enjoying an 80% reduction in corporate tax! From 20% to 4%. Due to Spain’s expansive network of international tax treaties there’s no need to hide profits! Experienced CFO’s know these components allow them to enjoy the full and unrestricted movement of funds free from withholding tax.

Clients use the tax saving to, fuel growth often resulting in increased headcount. Others work with our Corporate Finance Team, in London, to accelerate the equity value of their companies in preparation for a higher IPO or exit value. Profit x Multiple: P x M =?

Equally, due to the diversity of the islands, combined with the fiscal incentives, some of our more entrepreneurial clients simply base themselves here for lifestyle reasons”.

Santa Cruz de Tenerife ZEC Tax Zone, 4% Corporate Tax, Onshore, European Commission Backed.

If you want to find out if your company or Intellectual Property would be better positioned in the Canary Islands please contact;


T: +34 674 136 977

“The Guardian” – Santa Cruz de Tenerife, Top 5 Places to Live & Work

Why Canary Islands is an Entrepreneurial Paradise, AND NOT a Fiscal Paradise!

The Guardian News published an article ranking Santa Cruz de Tenerife in it’s top 5 places in the world to live! But why has this popular tourist destination ranked so highly with business highflyers, and what secrets does it really have to offer?

Christopher Pennington, Founding member of CIC group was recently interviewed by another publication for British Airways’ inflight magazine as to why the Canary Islands have such a gravitational pull on industry and business leaders, with more than 600 international businesses recently establishing a base there.

“The Canaries have many reasons why they’re becoming a key place of influence for fast growing and profitable businesses. Being on the same timezone as London yet located withing the Eurozone is a key advantage. the islands have direct daily flights to more than 180 destinations and more than 400 weekly flights direct to the UK. The Corporate Tax Rate for International businesses in the Canaries is just 4% through the Onshore EU Tax Incentive (ZEC) which means fast growing companies reduce their corporate tax bill by 80% in some cases.

Cost of living in the Canaries is seriously lower than elsewhere in Europe, standard of living is high which is why companies find it easy to attract top talent.

Has helped US companies from SIlicon Valley to establish a management centre to conduct EU Operations Centre’s along with numerous UK companies looking to avoid Brexit uncertainty by establishing and EU subsidiary and maximise net profits. The stats show this will continue to be a viable option for fast growing global compmanies for many years to come”.

If you would like to know more about the Onshore EU Tax Incentives in the Canary Islands and how to create a corporate structure here, contact: 

or call +34 674 136 977

US & UK Companies, Choose Canary Islands for West Africa Investment

US & UK Companies, Choose Canary Islands for

EU & West Africa Base!


As an emerging market, West Africa offers many opportunities for established Western and Asian companies.

In West Africa alone there’s a potential workforce of 350 million people, the population has increased 5 fold since 1950 and the United Nations has ranked West Africa as the World’s Fastest growing region!

During the past 10 years the Canary Islands, (Highly Evolved Spanish Islands located approx. 250km from Morocco) have become the perfect location for both outward investing African companies wanting to enter the global markets via a European corporate structure, and global companies wanting to enter the African market.






The Canary Islands have had a gravitational pull on European tourists since the 1970’s, due to their ever developing infrastructure, and stable financial, political and legal European framework. Actually if you set foot in the Islands Capitals of Santa Cruz or Las Palmas,  today you’d be forgiven for thinking you’re were in any European city.

Here’s the 3 main reasons why international companies, like Kinrosschose the Canary Islands as their preferred location in which to manage and grow their African activities!


  • Europe’s Lowest Onshore Corporate Tax Location: Due to the proximity to their parent country of Spain, the Canary Islands are protected by a permanent legal status known as “Ultra Peripheral”. This means, unlike other locations in Europe that boast tax incentives, the Canary incentives will always be in place, providing long term security for investors. The corporate tax rate is just 4% through the ZEC incentive. Additionally they have another half dozen other tax incentives to benefit a wide spectrum of companies and investors. The Canary Tax Incentives are authorized by the European Commission and fully regulated by the Spanish Governments Tax Office, “Hacienda”.

  • Access to Talent: The Canaries have 2 universities producing graduates to European standards, equally the general population is of a European mentality, and often, bi-lingual due to decade of tourism on the islands. Capital Investment Consultants has successfully supported many international companies to establish their corporate structure in the Canaries and recruit staff locally and internationally. Our biggest success was recruiting 47 qualified engineers, 4 of whom PhD’s, from the local universities and abroad, some of whom left Apple in Ireland to join the team!

Lifestyle: There is a magic about the Canary Islands and in particular the Capital Cities of the two provinces provide the perfect equilibrium between work and leisure. The low cost yet high standard of living, European culture, secure legal, financial and social systems make them amongst the most desirable European cities to live and workas stated by “The Guardian UK”. The Canaries is a place that people are gravitating to. Excellent medical care, education, connectivity (400 weekly flights to the UK alone) make this really a Commercial Paradise, not a fiscal one. 

To find our more or register for one of Capital Investment Consultants CommercialDiscovery Visits, please contact;

Mobile: +34 674 136 977

UK Office: +44 (0) 203 966 0035

Santa Cruz de Tenerife ZEC Tax Zone, 4% Corporate Tax, Onshore, European Commission Backed.



Atari Founder Nolan Bushnell, Why Global Digital Companies are Setting Up Here?

Atari Founder Nolan Bushnell…

Why Global Digital Companies are placing their International Offices here?


You’d be forgiven for thinking every Tech Company with a global potential sets up in Silicon Valley, after all it is a hotbed for innovative and disruptive technologies!

Since 2010, CIC has advocated the Canary Islands as the perfect location to position European and international, operations. Today, companies are utilizing the Canaries for global trade and expansion, so much so in June 2015 CIC relocated the R&D operation of a Silicon Valley to Santa Cruz de Tenerife.

By coincidence, a few months later, Atari Founder, Nolan Bushnell, spoke at a conference on the Spanish Islands stating “If I were to set up a Tech Company now, I would choose the Canaries over Silicon Valley”!

Shared below are the 5 key reasons why online, digital, and tech companies have chosen the Canary Islands as their preferred location, becoming home to international companies for their back offices, customer contact support, and commercial expansion operations.

Political framework

The Canary Islands is part of Spain meaning they benefit from the European Union’s political and legal framework. Spain’s economy is the 5thlargest in the EU and 14thglobally, providing Investors and Entrepreneurs with confidence when growing a company.

Access to talent

The Canary Islands has two internationally recognised universities, a large young European educated workforce with many people speaking in both Castellano Spanish & English.

Tax incentives

Not many people know the Canary Islands actually have the lowest onshore corporate tax rate in Europe, just 4% for qualifying companies. Due to the extensive Tax Treaty network Spain has with other nations, repatriated dividends to other onshore jurisdictions are free from Withholding Tax. VAT, when invoicing within the Canaries, is just 7%, in many cases no VAT is applied when invoicing internationally.


Located approximately 1000 miles south of Southern Spain the Canaries have always been a logistical place of importance. They are the place where Christopher Columbus set sail to discover the New World, and in 2005 President Bill Clinton announced them as a Tri-Continental Platform connecting the Americas, Europe & Africa. With more than 400 weekly flights to the UK, and hundreds of weekly flights to other European Cities, it’s easy to see why they’re a Key European Investment Hub.


As you might imagine from the logistical position, the Canaries are blessed with year round spring weather. Known to the Romans as the “Fortunate Islands” since the 70’s tourism figures have risen to 13 million per year. The modern cosmopolitan culture in the Canaries consists of Al Fresco dining, outdoor sports and activities, additionally the cost of living and employment is considerably lower than mainland Europe, some estimations state 35-40% lower. This leads to a generally happier, more efficient and productive workforce. 

To find out how your business can qualify for the Canary Islands ZEC Tax Incentive contact;

Tel: +34 674 136 977

Why The Canary Islands are “NOT” a Tax Haven

With high profile cases of some of the world’s largest companies being scrutinised for what has been described as “Aggressive Tax Structures” it’s easy to understand why the simple mention of a “Tax Incentive” is met with fierce opposition from parts of society.

We’ve all heard the phrases… “Tax Dodgers” “Tax Cheats” “Elitists” etc.

Whilst for some companies those insults are probably valid, generally there’s a complete misunderstanding between Tax Evasion/Avoidance, and Tax Incentives.

Companies, and individuals, who set up corporate entities in jurisdictions where they do not live, or carry out commercial activity are what’s considered Tax Evasion and Avoidance, notice we don’t separate between the two, why? Because they’re at the same end of the scale, only a thin line divides them. Historically, Tax Avoidance/Evaision schemes involve inactive shell companies, not engaged in real business activity, and established for the sole purpose of taking tax revenues away from governments and society as a whole! This clearly creates a Win Lose scenario, and no matter how “Legal” it maybe, there’s clearly a deeper ethical issue at the forefront of peoples minds.

Tax Incentives, on the other hand, are at the complete opposite end of the spectrum. Not only are they legal, but transparent, tax is actually paid, and the incentives are agreed and accepted by governments and commissions. These incentives provide both social and economic development in addition to the obvious benefit to the corporate entity, clearly a Win Win scenario! 

It’s exactly this second scenario why The Canary Islands ARE NOT a Tax Haven!!!

The Canary Islands proudly boasts the lowest “Onshore” Corporate Tax Rate in Europe, just 4%. An incentive known as the ZEC, (Zona Especial Canarias) or Canary Special Zone.

Smaller Online Business Owners, Consultants and Coaches take advantage of the RIC, “Reserve Investment in Canary Islands” which allows a 90% tax break on profits reinvested meaning a corporate tax base rate around 3%.

Canary Islands ZEC Zone Tax Incentive

Why do these “Tax Incentives” differentiate the Canaries from “Tax Heavens”? Simply because they’re tied to economic diversity, employment or investment.

The Ethical Argument

It’s easy to argue Tax Incentives in other jurisdictions are unethical, at the very least they’re abused. When you can open a company without actually conducting actual business from that country, have no tangible physical presence in terms of employees or actual services being rendered, it’s understandable why people have an issue with the ethics surrounding offshore. The Canary Islands Tax Incentives, however, are completely unique due to the fact they’re onshore and linked to both social and economic requirements.

ZEC Companies must adhere to the qulifying criteria, which is directly linked to investment and exployment, making it the most trasparent Tax Incentive in the EU, giving certainty to the business owners.

Why does the ZEC exist?

The ZEC exisits due to the logistical position of the Canaary Islands, being so far away from its Mother Country, Spain. The Canaries, unlike Malta and Cyprus, has a special legal status, “Ultra Peripheral” protecting its fiscal incentives.

The main reason the ZEC exists is to create Social and Economic diversity by attracting international business to the islands. During the crisis unemployment rate in Canary Youth exceeded 33% the highest in Europe, yet they have a wealth of bi-lingual, university educated, young talent. When trying to argue Tax Incentives are unfair should remember when an area of your community (In this case the EU) is experiencing difficulty, it’s supported with funding from Tax revenues from member states!!!

By issuing Tax Incentives, enabling a region to self-sustain and develop itself, ultimately means less support is needed from the EU, allowing tax revenues from other members to be put to better use elsewhere!

Every company operating in the Canary Islands is subject to the normal statutory reporting in Spain, in fact, extra attention is paid to those companies receiving the tax benefit to ensure they’re in compliance with the rules agreed, not just by the Canary Government, but the Spanish Government and the European Commission!

Santa Cruz de Tenerife ZEC Tax Zone, 4% Corporate Tax, Onshore, European Commission Backed.

This ensures people cannot cheat the system, more importantly it provides additional comfort and security for the owners of companies utilising the benefit. Real Tax Incentives for Real Businesses. No Shell Companies and No need to hide your revenue, just 4% Corporate Tax clean & transparent, plus 0% Whithholding on Dividends when repatriated to a stakeholder based onshore. Find out more…

Brexit: 5 Reasons UK Business Owners are opening subsidiaries in the Canary Islands?

In recent months we’ve has seen an increase of British Business Owners opening company structures in the EU, largely due to the uncertainty of the Brexit negotiations. Many business owners have concerns as to how they can protect revenues by continuing to service EU customers, as well as those desiring to grow their client base further inside the single market.

With many locations to choose from, below are some of the reasons why clients are choosing the Canary Islands as their preferred location to trade across the EU.


1)   Transparent & Onshore

Being part of Spain and the EU, businesses can trade from the Canaries with confidence and complete transparency. They enjoy a secure political and financial framework and certainty that their structure is ethically sound.

2)   Low Onshore Corporate Tax Rates;

The Canaries enjoys special fiscal treatment with the full authority from the European Commission. For qualifying companies there’s a low Corporate Tax Rate of just 4%, VAT on the islands is 7% and for High Earners there’s up to a 90% tax break through a reinvestment incentives, reducing the effective tax rate to as low as 3% in some cases.

Canary Islands ZEC Zone Tax Incentive

3)   Base in the EU

Famous for its year round constant spring temperature the Canaries is one of the world’s most popular tourist destinations, however, since the year 2000 the main commercial cities of Santa Cruz de Tenerife and Las Palmas de Gran Canaria have attracted a mass of companies both small and large, the most recognizable being, AtoS, British American Tabaco, Rolls Royce and ENSCO. Offering the perfect platform to service clients across the continent in the single currency, it’s the ideal way to overcome Brexit uncertainties.


4)   Connectivity & Time Zone

Being one of the few places in the EU on the same time zone as London certainly has its advantages, combine this with affordable daily connecting flights to more than 180 destinations just 3-4 hours from major European cities, the commercial growth looks certain to continue.

5)   Standard of Living

The Canaries and Spain boasts Excellent Healthcare, ranking higher than both the UK and the US on the WHO league table. The cost of living is considerably lower than other countries which has seen many Expats relocate either completely or in part to the islands, running their businesses remotely. As the online trend continues to grow, more entrepreneurs and business owners are spending more time in the Canaries as part of their retirement and secession planning.



For more information contact:

Christopher Pennington,

M: +34 674 136 977,


Santa Cruz de Tenerife ZEC Tax Zone, 4% Corporate Tax, Onshore, European Commission Backed.