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V2319-25 ·1 December 2025 ·consulta-vinculante Low impact
Tax

Replacement of shares with shares having different economic rights generates taxable income in the taxable base

A holding company plans to amend its statutes to replace its current shares with two new classes having different economic and political rights. The DGT states that this operation is considered a share swap, requiring the inclusion of the difference between market and fiscal value in the taxable base.

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2025-12-01PublishedPublished 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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