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Given the following hypothetical situation:

  1. I have an S-Corp in the US which generates 300K USD annually
  2. I am a US citizen
  3. I am an EU citizen and reside in Spain
  4. I invoice the US S-Corp for 50K EUR per year (to live off of in Spain as a freelancer)
  5. The remaining ~240K USD stays in the S-Corp's US bank account

How does the Spanish Tax Agency view this situation?

  1. Would the S-Corp's total annual income need to be declared as personal income in Spain?
  2. Would the ~240K USD that remained in the S-Corp be taxed at a US corporate tax rate?
  3. Is only the invoiced income (the 50K EUR) considered personal income from the perspective of the Spanish Tax Agency? Or is the S-Corp's total income included?

I tried understanding the tax treaties between both nations but it was unclear to me how this situation should be classified.

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