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V0653-25 ·10 April 2025 ·consulta-vinculante Low impact
Tax

Direct transfer of shares to shareholders is not a split and is taxed as dividend

The DGT confirms that the transfer of a subsidiary's shares to shareholders does not constitute a partial financial split, as there is no beneficiary entity or exchange. The transaction must be treated as a distribution of reserves or as a dividend in kind.

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2025-04-10PublishedPublished 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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