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V2473-23 ·14 September 2023 ·consulta-vinculante Medium impact
Tax

The application of the tax neutrality regime in contributions of shares is conditional upon the absence of tax fraud or evasion

The DGT clarifies that the special regime for non-monetary contributions does not apply if the main objective is tax fraud or evasion, or if the purpose is merely a fiscal advantage without genuine economic reasons such as business reorganisation or rationalisation.

In 6 key points

How it affects those involved

The regime for non-monetary contributions is restricted to cases with genuine economic motives, excluding tax fraud or purely fiscal advantages.

Lifecycle

2023-09-14PublishedPublished 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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