Skip to content
V2841-23 ·20 October 2023 ·consulta-vinculante Medium impact
Tax

Applicability of the fiscal neutrality regime in share exchanges under LIS requirements

A taxpayer asks whether transferring shares between two entities to a holding company through share exchanges allows the application of the special fiscal neutrality regime. The DGT responds that it applies if the beneficiary entity obtains a majority of voting rights and the conditions of Article 80 of the LIS are met, provided the transaction is not primarily aimed at fraud or tax evasion.

In 6 key points

Lifecycle

2023-10-20PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

Does this provision affect you?

The tax team reviews your specific situation.

Talk to the tax team
This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
Email
Contact