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V2427-25 ·11 December 2025 ·consulta-vinculante Low impact
Tax

Possibility of applying fiscal neutrality in transferring a commercial society to a single shareholder (foundation)

A foundation owning 100% of a real estate leasing company asks whether transferring the entire society's assets to the foundation via dissolution without liquidation can qualify for fiscal neutrality. The DGT confirms that such a transaction may qualify under the LIS conditions, provided it does not aim primarily at tax fraud or evasion.

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2025-12-11PublishedPublished 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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