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V2334-23 ·17 August 2023 ·consulta-vinculante Medium impact
Tax

Share exchange regime requires LIS compliance and valid economic reasons

The consultant asks whether a share swap to gain control of two entities can qualify for the special corporate tax regime and whether it is valid for inheritance tax. The DGT responds that fiscal neutrality is possible if legal requirements are met and there is no fraud, and that holdings in the holding company may be exempt from inheritance tax if activity, ownership and management requirements are satisfied.

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2023-08-17PublishedPublished 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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