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V0650-15 ·23 February 2015 ·consulta-vinculante Medium impact
Tax

Share exchange and split transactions under special regime require majority shares to be transferred

The DGT confirms that share exchanges may meet the conditions for the special regime, but some splits do not qualify as they fail to transfer majority shares.

In 6 key points

How it affects those involved

Splits that do not transfer majority shares cannot benefit from the special regime, affecting tax treatment and structuring of corporate transactions.

Lifecycle

2015-02-23PublishedPublished 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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