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V2353-20 ·9 July 2020 ·consulta-vinculante Medium impact
FISCAL

Transfer of US LLC shares not taxable in Spain if not linked to real estate

A US company asks whether exchanging its LLC shares for Irish company shares creates a taxable event in Spain, and whether relocating the LLC to Spain triggers taxable income. The DGT confirms that the share exchange is not taxable under the US-Spain double taxation treaty and that moving the company's domicile to Spain does not generate taxable income.

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2020-07-09PublishedPublished 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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