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V1648-23 ·9 June 2023 ·consulta-vinculante Medium impact
Tax

Capital reduction with share issuance may be tax-exempt under LIS art. 21

A holding company asks whether a capital reduction to separate shareholders can benefit from the special regime for mergers and spin-offs to exempt capital gains. The DGT clarifies that this is not a merger or split transaction, but capital gains from share transfers may be exempt if the requirements of participation and holding under LIS art. 21 are met.

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2023-06-09PublishedPublished 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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