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V2699-23 ·4 October 2023 ·consulta-vinculante Medium impact
Tax

Requirements for claiming fiscal neutrality in social share contributions

A physical person asks whether transferring shares in two entities to a third party may qualify for the special regime of fiscal neutrality. The DGT states this is possible if minimum participation, length of ownership, and the receiving entity not being a wealth management entity are met.

In 6 key points

How it affects those involved

The ruling clarifies conditions under which share transfers between companies may qualify for fiscal neutrality, affecting corporate restructuring and shareholding strategies.

Lifecycle

2023-10-04PublishedPublished 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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