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V0218-26 ·4 February 2026 ·consulta-vinculante Medium impact
Tax

Non-cash property contributions with debt may trigger ITPAJD tax

A company asks whether the non-cash contribution of property, including associated debt, qualifies for tax neutrality in corporate income tax and exemption under ITPAJD reorganisation rules. The DGT confirms tax neutrality in corporate income tax, but the portion of the contribution corresponding to the debt constitutes a taxable patrimonial transfer under ITPAJD.

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2026-02-04PublishedPublished 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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