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V2339-23 ·17 August 2023 ·consulta-vinculante Medium impact
Tax

Possibility of applying fiscal neutrality to non-monetary share contributions

A taxpayer asks whether contributions of shares in two entities to a new company (NEWCO) may qualify for the special restructuring regime. The DGT states that this is possible if the minimum shareholding, uninterrupted ownership, and absence of purely fiscal motives are met.

In 6 key points

How it affects those involved

Contributors may benefit from fiscal neutrality under specific conditions when transferring shares to a new company.

Lifecycle

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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