MONTCLARE
CAPITAL PARTNERS
The Zona Especial Canaria (ZEC) is a special economic zone within Spain and the European Union offering a reduced corporate income tax rate of 4% — against the standard ~25% — to companies that establish genuine activity and substance in the Canary Islands. Fully EU-compliant and authorised by the European Commission.
Montclare structures the ZEC for international investors from outside Spain — from the Gulf, Latin America, Asia and Africa — as a low-tax entry point into the European Union, held under a Dutch holding for treaty access, substance and exit optionality: a complement to the Dutch platform, never a substitute for it. Spanish-resident clients are served directly by our partner Fimax.
We work hand in hand with Fimax, our trusted Canary Islands partner — combining Montclare's cross-border structuring with their on-the-ground ZEC expertise, from eligibility through authorisation and ongoing compliance.
The ZEC covers a broad range of activities. Among the strongest fits:
ZEC's 4% rate combined with Canary Islands film and audiovisual incentives.
Software, digital services and technology companies.
International wholesale trade and distribution, including triangular trade. A pure holding company does not qualify: the ZEC list of admissible activities excludes the mere holding of participations, as well as financial intermediation and insurance.
Manufacturing, assembly and distribution operations.
Consulting, engineering and B2B service companies.
Online businesses serving EU and international markets.
The reduced rate applies to the part of the taxable base attributable to activity genuinely carried out in the islands, and only up to a ceiling set by headcount: EUR 1,800,000 where the minimum job creation is met, increased by EUR 500,000 for each job above the minimum, up to fifty jobs. Above fifty employees no ceiling applies. Base above the ceiling, and base attributable to activity performed elsewhere, is taxed at the general Spanish rate. We confirm the figures applicable to your case against the authorisation in force before any commitment is made.
The ZEC’s current authorisation runs to 31 December 2026, and entities entered in the Official ZEC Register within that window may apply the regime until 31 December 2032. An extension requires prior European Commission authorisation. Anyone considering the regime should treat the registration window, not the tax rate, as the binding constraint on the timetable.
Figures per the ZEC regime (Art. 28 et seq., REF Canario). Certain requirements are modulated by island and by activity; we confirm the figures applicable to your case against the authorisation in force. Subject to ZEC Consortium authorisation, which grants ZEC status. Montclare and Fimax coordinate through licensed local providers; a Spanish notary executes the incorporation. We help confirm the exact figures for your case with your advisers.
A founder-led digital platform group asked whether its software, platform management, technical support and commercial operations could move into a Canary Islands ZEC environment while keeping the group clean, defensible and operationally real.
We advised on the full holding-to-operating structure: ZEC eligibility, permitted activities, employment and local substance requirements, investment thresholds, governance and intercompany flows. We helped define a software/IP company under the holding, separated brand rights from operational IP, and reviewed transfer pricing and royalty documentation alongside the client's own advisers.
A clearer ZEC operating model across three Canary Islands entities, a defensible internal software licensing model, and a clean distinction between holding-level brand value and ZEC-level technology activity, where conditions are met.
Ten questions that establish, before you spend anything, whether the Canary Islands regime is genuinely available to you. It rewards moving an operation, not moving an invoice.
DOWNLOAD THE CHECK · PDFWe do not name clients. Discretion is part of the service.
An international company in software and digital services, planning between five and fifty employees on the islands, wanted to move real activity to the Canary Islands under the ZEC regime. It knew the reduced rate. It did not know whether its activity was eligible, what substance would be required, how many people it needed to hire, what minimum investment applied, or how the operation would be defended before the ZEC Consortium.
Outcome. The client received a defined route to ZEC authorisation, incorporation, hiring, investment and launch. Where the activity is eligible and the regime is genuinely implemented, qualifying income is taxed at the reduced ZEC rate of four per cent rather than the general Spanish corporate rate of twenty-five per cent (smaller companies apply a reduced scale, so the differential is narrower for a small operation than the headline suggests), conditional throughout on meeting the investment, employment and activity requirements.
Tell us about your activity and we will assess whether ZEC fits — with Montclare and Fimax.
REQUEST A ZEC ASSESSMENTThis page is informational and does not constitute tax, legal or investment advice. Figures describe the regime in general terms and are subject to the authorisation in force, to the conditions applicable to each activity and to change. Eligibility, thresholds and limits are confirmed for each case before any commitment is made. Each engagement is subject to scope and applicable regulation.