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V1896-25 ·14 October 2025 ·consulta-vinculante Low impact
Tax

Fiscal neutrality possible in non-cash contribution and total split under certain conditions

The consultation examines whether a reorganisation involving a non-cash property contribution followed by a total split may qualify for fiscal neutrality. The DGT confirms this is possible if participation and proportionality requirements are met, and the objective is not fraud.

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2025-10-14PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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