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V2330-23 ·11 August 2023 ·consulta-vinculante Medium impact
Tax

Requirements for fiscal neutrality in share swaps, non-cash contributions and mergers

A taxpayer asks whether a series of corporate restructurings—including share swaps, non-cash contributions and mergers—can benefit from the fiscal neutrality regime. The DGT responds that such arrangements may qualify provided the legal requirements of ownership, residency and valid economic motives are met.

In 6 key points

How it affects those involved

Taxpayers involved in corporate restructurings may benefit from fiscal neutrality if specific legal conditions are satisfied.

Lifecycle

2023-08-11PublishedPublished 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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