Investment vehicles: where should your wealth live?

Two identical estates can earn the same gross return and, fifteen years later, differ by millions of euros. The difference is not the investment. It is the vehicle through which it is made. Choosing the right structure is probably the most profitable tax decision an investing family can take.

The question weighs even more for anyone investing in Spain, or considering moving their residence here. Spain taxes net wealth (with a state solidarity tax on large fortunes from €3 million) and the savings base of personal income tax reaches 30% on gains above €300,000. Every euro paid along the way is a euro that stops compounding.

Private equity (ECR): the most efficient vehicle for investing in companies

Private-equity entities (companies or funds supervised by the CNMV) receive the best treatment of any unlisted investment. Gains on the sale of their holdings are 99% exempt from corporate income tax, provided the sale takes place between the second and the fifteenth year of ownership. Dividends from those holdings are also exempt.

In practice, a €4 million gain inside an ECR is taxed at around €10,000. The same transaction made directly by an individual would cost more than a million euros in personal income tax.

The trade-off is compliance: the ECR must keep at least 60% of its assets invested in unlisted companies and bear a regulatory cost (registration, management company, audit). It is a vehicle for someone with scale and a real private-equity purpose, not for parking passive wealth.

SOCIMI: rental property at 0% corporate tax

For families with a meaningful portfolio of urban property let out, a SOCIMI can be taxed at 0% corporate income tax. In return, it must distribute most of its profit as a dividend (at least 80% of rental income), and the shareholders are taxed when they receive it.

It requires a minimum capital of €5 million, 80% of assets and income to be real estate, and a listing on a market such as BME Growth. It suits families who want periodic income and professional management; less so those who prefer to accumulate and reinvest without distributing.

Investment funds: reorganise the portfolio without paying along the way

The transfer regime lets money move from one fund to another without tax until the final redemption. The tax that is not paid stays invested and earns a return. If the funds are held until the holder’s death, the accumulated gain is not taxed as personal income tax.

One important nuance: ETFs do not enjoy the transfer regime. Each sale of an ETF at a gain is taxed in that year. For deferral, traditional funds.

Unit-linked: deferral and an orderly succession

A life policy linked to a basket of investments defers tax until surrender, like a fund. Its distinctive value is in succession: on death, the capital goes directly to the named beneficiary, outside the estate. That gives the heirs immediate liquidity, for example to pay inheritance tax.

Two warnings: the policyholder cannot choose the specific investments (or the deferral is lost), and a unit-linked policy does count for wealth tax.

SICAV: no longer a family vehicle

For years, the SICAV was the reference tool for financial wealth, taxed at 1%. Since 2022, each of the minimum 100 shareholders must have at least €2,500 invested. Close to 80% of SICAVs have disappeared. Creating one for a family no longer makes sense. Reviewing those that still exist, and relocating their assets, does.

Which vehicle for which purpose

Vehicle	Main tax advantage	For whom	Key condition
ECR	99% exemption on gains	A family office investing in companies	60% of assets in unlisted holdings
SOCIMI	0% corporate income tax	A portfolio of rental property	Distribute the profit and list
Investment funds	Full deferral through transfers	Liquid financial wealth	Does not work with ETFs
Unit-linked	Deferral and succession liquidity	Someone who wants to organise the estate	Does not take the wealth out of wealth tax
SICAV	1% only with a real shareholder base	Review of existing SICAVs	100 shareholders with €2,500

The point: the structure as a whole

These vehicles rarely work alone. They usually sit under a family holding company and are coordinated with succession planning and wealth tax. A poorly fitted ECR can lose the family-business exemption; a SOCIMI may make no sense if the family does not want income.

For the international investor there is a further layer: the double-tax treaty with their country, treatment as a non-resident and, if they move to Spain, the special impatriate regime. The right vehicle depends on where they live today and where they want to live tomorrow.

At Altura we look at the estate as a whole (tax, legal, financial and real estate) before recommending any vehicle. If you want to know which structure fits your case, let’s talk.

This article is for information only and is not advice. The rules cited are those in force in October 2026; each case needs its own analysis.