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V2080-23 ·14 July 2023 ·consulta-vinculante Medium impact
Tax

Fiscal neutrality regime for non-cash contributions requires minimum 5% shareholding

The DGT confirms that the special regime applies to share contributions exceeding 5%, but not to those below 5%.

In 6 key points

How it affects those involved

Companies making non-cash contributions below 5% do not benefit from the special tax regime, affecting their restructuring options.

Lifecycle

2023-07-14PublishedPublished 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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