1. Purpose
This appendix sets out additional considerations for Murzo Group activity connected with Spain. It supports the wider international, customs, tax, product, food, property, and overseas work policies.
The purpose is to prevent Murzo Group from treating Spain as simply another shipping destination when activity may create EU, Spanish, regional, municipal, tax, employment, property, product, food, farming, or consumer obligations.
2. Scope
This appendix applies to selling into Spain, importing into Spain, buying from Spanish suppliers, storing goods in Spain, recruiting or posting workers to Spain, using Spanish agents or distributors, acquiring or leasing property in Spain, attending exhibitions, and carrying out farming, food, design, fashion, security, or cultural property activity in Spain.
3. Market Entry Checks
Before starting Spanish activity, Murzo Group should identify whether the activity is a one-off sale, B2B supply, B2C supply, local project, local establishment, local employment arrangement, property transaction, regulated product supply, or ongoing Spanish market presence.
Spain is an EU member state, so EU product, VAT, customs, consumer, data, food, environmental, and market surveillance rules may apply alongside Spanish national and regional rules.
4. Tax, VAT, EORI and NIF
Murzo Group should check whether Spanish VAT registration, EU OSS or IOSS, fiscal representation, local tax identification, NIF, EORI, customs representation, or Spanish tax advice is needed before selling, importing, storing, or supplying goods or services in Spain.
Using a UK VAT or customs position does not automatically satisfy Spanish or EU requirements.
5. People, Posted Workers and Employment
Workers travelling to Spain must have the correct immigration, posted worker, social security, health and safety, insurance, and local labour position for the activity being performed.
Murzo Group must not use repeated business visits, consultants, or local contractors to avoid Spanish employment, payroll, agency, health and safety, or social security rules.
6. Product, Food and Farming Controls
- Check EU and Spanish product safety, labelling, language, market surveillance, consumer, and conformity requirements
- Check food, feed, allergen, ingredient, nutrition, health claim, novel food, animal product, plant health, organic, and border control requirements
- Check farming, land, water, environmental, pesticide, substrate, insect, biosecurity, and local licensing requirements
- Check packaging, EPR, waste, batteries, WEEE, textiles, and digital product passport readiness where relevant
- Check customs, origin, valuation, and import responsibility where goods enter Spain from outside the EU
7. Property and Facilities
Property acquisition, leasing, farming land, storage, offices, showrooms, facilities, or operational sites in Spain require review of title, permissions, zoning, environmental, tax, insurance, utilities, health and safety, security, and local authority obligations.
This appendix should be read alongside the Real Estate Acquisition, Leasing & Facilities Management Policy.
8. Agents, Distributors and Local Partners
Spanish agents, distributors, consultants, local partners, and introducers must be assessed under the Foreign Agents, Distributors, Local Partners & Commission Payments Policy.
Murzo Group should avoid creating a dependent agent, permanent establishment, unauthorised employment relationship, or unapproved authority to bind Murzo Group in Spain.
9. Required Evidence Only
Spain-specific tax, customs, product, employment, property, partner, and authority evidence should be limited to what is required by law, contract, adviser instruction, authority request, or practical need.
10. Review
This appendix will be reviewed when Murzo Group starts sustained activity in Spain, changes Spanish sales channels, appoints local partners, stores goods in Spain, hires or posts workers, or acquires or leases Spanish property.
