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V2752-23 ·10 October 2023 ·consulta-vinculante Medium impact
Tax

Share contribution to a new holding company may qualify for fiscal neutrality

A taxpayer asks whether contributing shares from a company to a new holding company allows use of the special corporate tax regime and whether this violates the obligation to maintain the acquisition in inheritance and gifts tax. The DGT responds that the transaction may qualify for fiscal neutrality and does not breach the obligation to maintain the acquisition in inheritance and gifts tax.

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2023-10-10PublishedPublished 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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