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V1655-25 ·15 September 2025 ·consulta-vinculante Medium impact
Tax

Requirements for applying the fiscal neutrality regime in share exchanges

A company proposes a share exchange whereby it transfers its full shareholdings in 15 entities to another entity in exchange for new shareholdings. The DGT states that the operation may be subject to the fiscal neutrality regime if the conditions of Article 80 of the LIS are met and the primary objective is not fraud.

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2025-09-15PublishedPublished 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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