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V1282-16 ·29 March 2016 ·consulta-vinculante Medium impact
Tax

Non-cash property contribution followed by a financial split does not qualify for special neutrality regime

A consultancy firm proposes a non-cash contribution of real estate to another company, followed by a financial split of its share. The DGT determines that the operation does not meet the requirements for the special regime of mergers and splits.

In 6 key points

How it affects those involved

The operation does not benefit from the special tax neutrality regime, which may affect the tax treatment of the transaction.

Lifecycle

2016-03-29PublishedPublished 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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