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V2827-20 ·21 September 2020 ·consulta-vinculante Medium impact
FISCAL

Cannot apply special non-cash contribution regime if recipient is a Russian resident without a permanent establishment in Spain

The DGT confirms that a contribution of Russian company shares to a new Russian entity (NEWCO) cannot benefit from the special non-cash contribution regime because the receiving entity is not resident in Spain and has no permanent establishment in Spain.

In 5 key points

How it affects those involved

Companies considering non-cash contributions to Russian entities must ensure the recipient is either resident in Spain or has a permanent establishment in Spain to qualify for the special regime.

Lifecycle

2020-09-21PublishedPublished 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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