How a Spanish Medical Clinic Owner Reduced His Tax Bill by €230,000 annually

The challenges they faced

1. Low visibility
   The clinic relied on referrals and walk ins with limited brand recognition outside its immediate neighborhood.

2. Zero international structure
   All income accrued in Spain under a single domestic company which exposed every euro of profit to Spanish corporate and personal taxes.

3. No residency planning
   The owner lived full time in Spain without a strategy to lawfully separate personal taxation from business income.

4. Compliance uncertainty
   There was confusion about double tax treaties, controlled foreign company exposure, and how to receive dividends without creating a new tax charge in Spain.

Our step by step approach

Step 1: Clarifying the strategy and timeline
We mapped the owners travel patterns, family ties, and professional obligations. We set a clear calendar for residency change that met day count tests and center of vital interests criteria, with documented evidence for future audits.

Step 2: Establishing a Maltese operating company
We created a Maltese trading company to service international patients and B2B partners. Contracts, invoicing, and banking were moved to Malta. The clinic delivered services to foreign clients through the Maltese entity where permitted, and Spanish domestic services remained ring fenced to stay compliant.

Step 3: Moving personal tax residency to Estonia
The owner relocated personal tax residency to Estonia with proper registration, local lease, local bank accounts, and community ties. Estonia does not tax most foreign source dividends received by residents when they meet the relevant conditions. This created a lawful pathway to receive distributions from abroad without a second tax charge.

Step 4: Treaty alignment and profit flow
We aligned payment flows under applicable double taxation agreements. The Maltese company paid corporate tax according to Maltese rules. After tax profits were declared as dividends to the Estonian resident owner. With treaty relief and the Estonian regime, the dividends were received without additional personal income tax.

Step 5: Banking, payroll, and documentation
We opened accounts in Malta and Estonia, set up a modest salary for optics and social security where needed, and prepared a complete substance file. This included board minutes, service contracts, transfer pricing memos, and day count logs to defend residency and source of income.