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V2293-20 ·6 July 2020 ·consulta-vinculante Medium impact
Tax

Canje of shares possible with voting majority and legal requirements

Consultants ask whether contributions of shares from multiple entities to a holding company may qualify for the special share exchange regime and whether valid economic justifications exist. The DGT confirms this is possible if a majority of voting rights is obtained and legal requirements are met, stressing that the purpose must not be purely fiscal.

In 6 key points

How it affects those involved

The regime allows share exchanges in holding companies when a majority of voting rights is acquired and legal conditions are met, provided the underlying purpose is not solely fiscal.

Lifecycle

2020-07-06PublishedPublished 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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