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A family group has requested clarification on whether contributing their shares in various companies to a recipient entity qualifies for the special tax neutrality regime. The Directorate General for Taxes (DGT) has ruled that eligibility depends on meeting specific requirements regarding voting rights majorities, tax residence, and minimum shareholding percentages.
This ruling clarifies the strict conditions necessary to benefit from tax neutrality during corporate restructurings involving share contributions, emphasizing the importance of maintaining control and specific ownership thresholds.
The tax team reviews your specific situation.
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