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V2755-23 ·10 October 2023 ·consulta-vinculante Medium impact
Tax

Possibility of applying fiscal neutrality to share contributions to a holding company

A physical person enquires whether contributing shares in several companies to their holding company may qualify for the special restructuring regime. The DGT responds that this is possible if the minimum shareholding, length of time, and absence of purely fiscal purposes are met.

In 6 key points

How it affects those involved

The ruling allows individuals to transfer shares to a holding company under a special tax-neutral restructuring regime, provided certain conditions are met.

Lifecycle

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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