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V1965-25 ·16 October 2025 ·consulta-vinculante Low impact
Tax

Share exchange to create a holding company may qualify for tax neutrality

A company wishes to transfer its shares in three distributors to a new company (NEWCO) via a share exchange to centralise management. The DGT determines that the transaction may apply tax neutrality if NEWCO obtains a majority of voting rights and there is no fraud.

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2025-10-16PublishedPublished 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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