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V1917-23 ·4 July 2023 ·consulta-vinculante Medium impact
Tax

Requirements for applying the special non-cash contribution regime

Individuals inquire whether contributions of social shares to a newly established Spanish resident entity may qualify for the special LIS regime. The DGT states this is possible provided the requirements on share capital percentage, uninterrupted ownership, and no primary objective of tax advantage are met.

In 6 key points

How it affects those involved

The guidance clarifies conditions under which non-cash contributions to new Spanish companies may qualify for the special LIS regime, ensuring alignment with tax neutrality and economic rationale.

Lifecycle

2023-07-04PublishedPublished 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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