What the ledger is telling us
Exposure findings, risks and recommendations in one queue, ranked critical first. Every item opens on the facts it was derived from — nothing here is typed by hand.
sphera-wealth-management-advisory
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 If the regime is repealed from 2027 he reverts to standard IRPF as a Spanish tax resident, bringing worldwide income into charge — dividends from Salvatierra Holdings Ltd (DIFC), gains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.
Because Lucas is ineligible for Beckham (prior Spanish residence 2020–2022), he is already taxed under standard IRPF on worldwide income and subject to Spanish wealth tax — a Beckham repeal changes nothing for him. His 25% beneficial interest in Duarte Global Ltd (DIFC) and its US portfolio is already fully within Spanish charge. This is the contrast case: the same move that shields Mateo leaves Lucas exposed today.
Helena is UAE tax resident (no personal income tax and no wealth tax). A change to the Spanish Beckham regime has no effect on her position despite her 25% beneficial interest in Duarte Global Ltd. Included to show the traversal correctly excludes non-Spanish-resident members.
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.