Manuel Alonso

Manuel’s practice focuses on the design and implementation of cross-border tax structures, advising clients on international taxation, corporate reorganizations and the tax implications of global business transformations. He regularly assists multinational groups in optimizing their international footprints, aligning tax planning with regulatory obligations and managing the tax impact of reorganizations, mergers, carve-outs and investment flows. His work includes advising on multijurisdictional income allocation, withholding tax exposure, tax residency matters and the structuring of inbound and outbound investments.

In the sports and entertainment sector, he counsels athletes, clubs, agents and sport investment vehicles on income structuring, image rights arrangements, transfer-related payments and personal tax exposure in multicountry scenarios. In the tech, media and film industries, Manuel advises on the tax treatment of intangible assets, licensing models, global revenue streams and the mobility of key executives, drawing on his experience in Silicon Valley to address tax challenges faced by digital and innovation driven businesses. His practice also involves guiding clients through interactions with tax authorities, ensuring regulatory compliance while maximizing tax efficiency.

• Advised a multinational group on the Spanish tax implications of dividend distributions from Spanish entities to foreign shareholders.
• Advised a multinational group on restructuring alternatives in Spain to achieve a simplified and tax-efficient structure, involving the migration of multiple tax transparent entities to Spain and a subsequent merger of several Spanish entities.
• Advised a global software company on withholding tax refund claims related to licensing income from Spanish customers, successfully securing multimillion euro refunds.
• Advised a Spanish holding company on the Spanish tax implications of dividend distributions from a Mexican operating entity.
• Assisted a major Spanish infrastructure operator in initiating withholding tax refund proceedings before the Portuguese tax authorities, coordinating the process with local counsel and achieving significant recoveries.
• Advised an international technology group on tax considerations for its global expansion strategy, including IP location, holding structures and substance requirements.
• Advised a multinational group on local tax implications of its activities in the Netherlands, the UK and Mexico, including permanent establishment risks, coordinating with Baker McKenzie offices in those jurisdictions.
• Advised a multinational group on a local transfer pricing study in India, in coordination with local advisors.
• Advised an aerospace company on the Spanish tax implications of a cross-border restructuring project aimed at establishing a joint venture with international partners.
• Advised a pharmaceutical group on the legal and tax aspects of acquiring real estate for new corporate headquarters, including full legal and tax due diligence.
• Advised a leading student housing and flexible accommodation platform on the potential restructuring of its group to assess eligibility for operating under the Spanish SOCIMI (REIT) regime. 
• Advised a major financial institution on structuring media financing transactions, including drafting agreements, analyzing tax incentives and assessing the financial viability of audiovisual projects.
• Advised multiple private equity and alternative investment firms on structuring carried interest arrangements for Spanish resident managers to ensure eligibility for favorable tax treatment. 
• Advised senior executives of listed companies, consulting firms and investment managers on the tax structuring of compensation packages, equity-based incentives and international mobility. 
• Advised a high-net-worth individual on the Spanish and Portuguese tax implications of a potential relocation, in coordination with Portuguese counsel.

• Madrid Bar Association