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V0085-24 ·15 February 2024 ·consulta-vinculante Medium impact
Tax

Contributor may contribute bare ownership of shares under tax neutrality regime

A taxpayer asks whether they can contribute both full and bare ownership of shares in a holding company to a new entity without tax. The DGT responds that the status of shareholder rests with the bare owner and that the transaction may qualify under the non-monetary contributions regime if legal requirements are met.

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2024-02-15PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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