Thank you for your input, very helpful. That is what I am trying to achieve... a tax-effective way and still stay on the legal sideYou employ these persons in a Spanish company, also you can work in this company, however, Spanish company could be engaged in low added value operations and work as a “service center” on a cost-plus basis (all salaries plus other costs and plus 5% mark-up). Spanish company might issue an invoice to other companies in more tax-favorable jurisdiction (Cyprus, Malta or any other depending on your situation). It is important that this other company would be properly structured and would have economic substance. If it did not have substance previous comments as regards “permanent establishment” would be applicable. So I think it is possible to structure your business in a more tax-effective way and still stay on the legal side, but it also might be costly.