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V1911-23 ·4 July 2023 ·consulta-vinculante Medium impact
Tax

Possibility of applying fiscal neutrality regime in share exchange and total spin-off operations

Some partners inquire whether exchanging their shares in two companies to establish a holding and subsequently carrying out a total spin-off of one of them may qualify for the fiscal neutrality regime. The DGT responds that such operations may apply if legal requirements are met and there is no primary objective of tax fraud or evasion.

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2023-07-04PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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