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V1962-16 ·9 May 2016 ·consulta-vinculante Medium impact
Tax

Inclusion in the tax base of the difference between the market value of assets received and the tax value of the shareholding upon dissolution

The query examines how a company should be taxed upon the dissolution and liquidation of a company in which it holds a stake. The DGT rules that the income resulting from the difference between the market value of the assets received and the tax value of the cancelled shareholding must be included in the tax base.

In 6 key points

How it affects those involved

This ruling clarifies the tax treatment of gains arising from the liquidation of subsidiaries, ensuring that the difference between market value and tax book value is correctly recognised as taxable income.

Lifecycle

2016-05-09PublishedPublished 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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