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MEDIUM
FISCAL

Requirements for applying the fiscal neutrality regime in share exchanges

V1655-25

Prepared and reviewed by the BMC editorial team  ·  Methodology

Technical details

Type
consulta-vinculante (what is this?)
Identifier
V1655-25
Published
15 Sept 2025

Summary

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.

In 6 key points

Lifecycle

2025-09-15PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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