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V2389-23 ·5 September 2023 ·consulta-vinculante Medium impact
Tax

Full and bare ownership of shares may qualify for fiscal neutrality

A natural person enquired whether the bare ownership and full ownership of shareholdings in a new holding company could benefit from the fiscal neutrality regime. The DGT responds that the bare owner has the status of shareholder and may make the contribution, provided the requirements of Article 87 of the LIS are met and there is no primary objective of tax fraud or evasion.

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2023-09-05PublishedPublished 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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