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A query was raised regarding whether the contribution of shares from a Spanish company to an Andorran company is subject to ITPAJD. The DGT ruled that the tax does not apply to corporate transactions as they take place outside Spain, nor to documented acts as they cannot be registered in the relevant registries.
The ruling clarifies the territorial scope and registration requirements for ITPAJD, confirming that cross-border share contributions to non-Spanish entities fall outside the tax's scope.
The tax team reviews your specific situation.
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