Saved €12,400 in avoidable non-resident tax on a €340k purchase.

The client came in through a Costa Larga discovery call with a specific brief: a coastal apartment to add to a small portfolio already running in the Netherlands, target gross yield above 6%, willing to hold for 8–10 years. He had a property in mind from a Dutch-language agent he had worked with for years — €340,000, €1,950 a month rental projection.

What the agent's plan looked like

The default purchase structure proposed by the agent's recommended lawyer: buy as a Dutch individual, file Modelo 210 quarterly, income tax in the Netherlands, treaty credit, done. On paper, the straight line.

Costa Larga's first run of the numbers came back with a different conclusion. The Dutch box-3 system at the time taxes a deemed return on net wealth, and the rental income from a Spanish property is taxed in Spain at 19% (deductible expenses, EU treatment) but the underlying capital is also picked up by box 3. The double layer was the issue. With this client's existing portfolio, the marginal box-3 hit was meaningful.

The intervention

Two weeks before arras, we ran a side-by-side analysis of three structures:

1. Direct as individual — the agent's plan.
2. Spanish SL (limited company) — Spanish tax resident company, 25% on profits, but full expense deductions including depreciation, and Spanish corporate distributions taxed differently in NL than direct rental income.
3. Dutch BV holding the Spanish asset — corporate non-resident in Spain, more administrative weight, but cleaner treatment of long-term capital gains.

For this client's profile — 8-year hold, mid-six-figure rental intake, existing Dutch corporate structure — option 2 produced a clearly lower lifetime tax bill once depreciation, planned renovation capex, and the eventual disposal were modelled.

The before/after

Why the timing mattered

Restructuring after arras is expensive. The Spanish company has to be incorporated, NIE issued, bank account opened, and the arras assigned to the company before signature at notary — assigning is possible but adds notary cost and triggers a separate ITP analysis. Doing it before arras meant the company name was on the contract from day one. No assignment, no extra notary, no additional ITP exposure.

That sequence is only possible if the tax advisor is at the table before the agent has been chosen. By the time arras is drafted, the structure has already been baked in. This is the single most expensive sequence error we see and the reason this practice exists at all.

The outcome

The Spanish SL was incorporated in week 4. NIE for the client and the company in week 5–6. Arras signed in the company's name in week 7. Notary in week 11. Property entered the rental market via VITA Host in week 13.

One year on, the file is producing the modelled net cash. The tax delta vs. the original plan is on track for the €12,400 over eight years. The structural decision will continue to compound for the entire holding period.