Skip to content
V0906-26 ·24 April 2026 ·consulta-vinculante Medium impact
Tax

Fiscal neutrality regime applicable in share exchange if legal requirements met

A consultant asks whether a share exchange enabling one entity to acquire control of another meets the special regime conditions for mergers and spin-offs. The DGT responds that such a regime may apply if the conditions in Article 80 of the LIS are met and the objective is not fraud or tax evasion.

In 6 key points

Lifecycle

2026-04-24PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

Does this provision affect you?

The tax team reviews your specific situation.

Talk to the tax team
This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
Email
Contact