Tramita[X] · Internal
Business Plan
- Version
- v0.1 — internal working draft
- Last updated
- Audience
- Co-founders + prospective business partner
The Business
A modern, trustworthy filing service for Spain's Modelo 210 — the annual non-resident income tax that every foreign property owner in Spain must file. The customer is a non-resident landlord or second-home owner (primarily Dutch, German, British) who currently either uses a local Spanish gestor (€250+/year, trusted but old-fashioned, language barriers) or an anonymous online tool like IberianTax (€35–80, cheap but impersonal).
We sit between them: a clean online experience backed by a named, accredited Spanish asesor fiscal who reviews and files every return. Peace of mind, real human in the loop, communication in the customer's language, modern digital flow — without gestor prices.
Customer Acquisition Strategy
The customer does not choose us — the recommender does. Most non-resident landlords find their tax filer through:
- The property management or maintenance company that manages their rental
- The agency that handles their letting
- A friend or neighbor who recommended someone
This is a B2B2C business with a consumer-facing brand. The actual go-to-market is building a network of 20–50 property managers, rental agencies, and maintenance companies across Costa Blanca, Costa del Sol, Mallorca, and Tenerife who recommend us.
Year 1: one anchor partner (a Spanish property-management agency the founders have a relationship with). Execute one filing season flawlessly, capture testimonials and metrics.
Year 2: Outreach to 30+ additional agencies using Year-1 data. Offer agencies their choice of revenue share (€20–30/filing kickback), white-label option, or free agency-side dashboard for managing all their owners' filing status.
Year 3: Become the default recommendation in 2–3 coastal regions. Word-of-mouth between owners begins to compound.
Operating Model
- Two technical co-founders based in the Netherlands handle product, customer experience, and growth.
- Two Spanish asesores fiscales (registered colaboradores sociales with AEAT) are contracted to review and file every return. They sign the filing — we don't.
- The software does intake, document collection, validation, draft preparation, customer communication, and handoff. The Spaniard reviews each draft in 5–15 minutes and submits to AEAT.
- Always have two partners from day one for continuity (one as primary, one as backup with a small retainer of €200–500/month). January peak is brutal — single point of failure is unacceptable.
Pricing
- Customer pays: ~€180 per filing (positioned as 25–30% cheaper than a traditional gestor at €250, premium relative to IberianTax at €80).
- Paid to Spanish partner: ~€80 per filing.
- Gross margin to us: ~€100 per filing.
- Optional agency kickback: €20–30 per filing where applicable.
- Net contribution to founders: €70–100 per filing depending on channel.
Pricing must be justified by visible human review — the customer needs to feel the Spanish professional in the loop (named, accredited, signature on filing receipt). Otherwise we look overpriced versus IberianTax.
Product Scope
Phase 1 (build first, 8–12 weeks)
- Consumer-facing intake flow (English first, Dutch added before launch given anchor partner's audience)
- Document upload (IBI receipt, NIE, ownership details)
- Validation layer (NIE format, cadastral value sanity checks)
- Customer dashboard with status tracking
- Internal partner tool for the Spaniard to review pre-filled drafts and submit
- Confirmation flow including AEAT receipt and partner's name/credential visible to customer
Phase 2 (only if Phase 1 traction justifies, Year 2)
- Agency partner portal: bulk view of all owners under one agency, filing status, deadline alerts, bulk reminders, compliance reports for the agency. This is the real long-term moat — agencies who use this won't switch.
Not building
- Marketplace of professionals (not bootstrap-compatible)
- AI receipt OCR / year-round portal (until customers explicitly ask and pre-pay)
- Aggressive deduction engines (legal risk, see below)
- Anything beyond imputed-income and rental-income filings in Year 1 (no capital gains, no back-filing until Phase 2)
Legal and Liability Framework
Filing model: the Spanish partner files as colaborador social under their own credentials and signature. We are not the filer. This is non-negotiable for liability containment.
Our liability exposure (which is real and not zero)
- Consumer-facing accuracy: Dutch consumer law (Art. 6:193a–j BW on misleading practices, Art. 7:24 BW) limits how aggressively we can disclaim liability for B2C services. T&Cs must clearly state the filing is performed by a named Spanish professional, and that professional's name must appear on the customer's filing receipt.
- Data layer: if our software miscalculates an input that the Spaniard then files, the loss traces back to us. We must build: input validation, customer review/approval step before submission, double-entry confirmation for key numbers.
- Recommender misrepresentation: website must never claim “we file your taxes” — frame as “we help you prepare and connect you with an accredited Spanish asesor fiscal who files your return.”
Required from the Spanish partner
- Active colaborador social status with AEAT (verify certificate, not just claim)
- Active professional indemnity insurance with sufficient cap (review policy, request copy)
- Membership in a recognized professional body (Colegio de Economistas / REAF, Colegio de Gestores Administrativos, or AECE)
Our own protections
- Dutch BV as operating entity (limits founder personal liability if properly capitalized)
- Professional indemnity insurance for the BV (~€1,000–3,000/year for €1–2M coverage)
- T&Cs reviewed by a Dutch lawyer in Year 1 once revenue justifies it (~€1,500–3,000)
- VAT setup: OSS scheme for B2C digital services across EU; reverse-charge on the B2B service from Spanish partner; Dutch accountant to set this up properly from day one (~€500–1,000 one-off)
Spanish partner agreement (critical pre-build)
- Drafted in Spanish by a Spanish lawyer experienced in service agreements (~€800–1,500)
- Must cover: fixed fee per filing (and renegotiation triggers at volume), exclusivity terms, termination clauses, customer data ownership, non-compete on customer relationships, IP ownership
Regulatory and Market Risks
Acknowledged risks that must be monitored:
- July 2025 Audiencia Nacional ruling (SAN 3630/2025): non-EU residents may be entitled to deduct rental expenses, currently under appeal to the Supreme Court. We will not apply this deduction in our standard flow until the Supreme Court confirms — conservative defaults. We may build a separate “claim refund for prior years” product once the legal position is settled, as the 4-year reclaim window is significant.
- European Commission challenge to imputed income tax on personally-used non-resident property: if struck down, half the empty-property filing volume disappears. Cannot be mitigated, but accelerates the case for rental and back-filing products as primary offerings.
- Filing schedule change (already in effect): since tax year 2024, rental income is filed annually (1–20 January) rather than quarterly. Our entire system is designed around the annual model.
- February 2026 short-term rental data declaration: new compliance obligation for STR owners — potential additional product line.
Co-Founder Pre-Build Actions
Before writing any production code, the following must be done in order:
- Co-founder agreement on paper: equity split, roles, time commitment, vesting/cliff, exit and dispute clauses, IP assignment. Dutch lawyer drafted, signed by both founders.
- Anchor agency conversation: hard number on filings they could route to us, what they'd pay/charge owners, capacity in January, willingness to partner formally. If this is vague, the whole plan is much weaker.
- Five customer conversations with the anchor agency's existing owners (introduced by the agency): current process, willingness to pay, pain points, deduction frustrations.
- Two Spanish partner candidates identified and vetted: in-person visits, verify colaborador social status, professional indemnity insurance, capacity at peak, current tooling. Draft partner agreement reviewed.
- Dutch BV incorporation with appropriate capital, VAT registration, OSS registration for cross-border B2C.
- Domain set secured (
tramita…family across .es + .eu + .nl + .de + .co.uk + .fr at minimum). EU trademark search at euipo.europa.eu before public commitment to brand.
Realistic Economics
This is a bootstrapped cash-flow business, not a venture-backed startup. No exit assumed.
- Year 1: 100–300 filings via anchor agency. Revenue €18–54k. Net contribution €7–30k. Built nights/weekends; founders not yet full-time.
- Year 2: 300–800 filings as more agencies onboard. Revenue €54–144k. Net contribution €21–80k. One founder potentially full-time.
- Year 3: 800–2,500 filings. Revenue €144–450k. Net contribution €56–250k. Both founders potentially full-time.
- Year 4–5 ceiling: 2,500–5,000 filings. Net contribution €175–500k/year to two founders.
This is a €200–500k/year profit business for two people within 3–4 years if the agency channel works. It is not, and is not intended to be, a venture-scale outcome.
Top Risks, Ranked
- Agency channel turns out smaller than the friend claims. Checkable this week — must be confirmed before building.
- Spanish partner hits capacity in Year 2 and quality drops. Mitigated by having two partners from day one.
- IberianTax launches a “premium” tier with human review at €120 and squeezes our positioning. The real strategic risk — agency moat must be built before they react.
- EC ruling kills imputed income tax requirement. Cannot mitigate; must diversify product line into rental, back-filing, capital gains.
- Spanish tax law changes mid-season. Retain a Spanish tax advisor on small monthly retainer (€500–1,000) for ongoing monitoring and ad-hoc questions.