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V2078-23 ·14 July 2023 ·consulta-vinculante Medium impact
Tax

Non-cash contributions may qualify for fiscal neutrality if conditions met

A natural person asks whether contributions of shares from two companies to a new entity (NEWCO) can benefit from the special regime of fiscal neutrality. The DGT states this is possible provided the requirements of shareholding, duration, and business activity are met, and the transaction is not primarily aimed at tax fraud or evasion.

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2023-07-14PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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