Familia Salvatierra-Rivas
sphera-wealth-management-advisory
The same queue as the Insight Queue, scoped to Familia Salvatierra-Rivas. Each item opens on the facts it was derived from.
Mateo currently benefits from Beckham: Spanish-source employment income flat-taxed at 24% and non-Spanish income excluded. If the regime is repealed from 2027 he reverts to standard IRPF as a Spanish tax resident, bringing worldwide income into charge — dividends from Salvatierra Holdings Ltd (DIFC), gains on the USD 18.5M global portfolio held through the DIFC holdco, and rental/US income via the US LLC — plus Spanish wealth tax on worldwide net assets. He beneficially controls 60% of the DIFC holdco, so 60% of holdco-level income and assets is attributable to him. Estimated incremental annual exposure ~EUR 1.18M.
Mateo currently benefits from the Beckham regime through tax year 2029. Given proposals to restrict the regime, model a 2027 repeal now: incremental worldwide-income and wealth-tax exposure is estimated at ~EUR 1.18M/yr, driven by his 60% beneficial interest in the DIFC holdco and the global portfolio. Recommend reviewing distribution timing and considering a partial UAE-anchored holding for post-2029 continuity. Advisor to confirm; this is defensible on the signed facts.
Sofía is Spanish tax resident but holds no direct beneficial stake in the structure and has not elected Beckham. A repeal has no direct effect on her; exposure is indirect via the household only.