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V3105-14 ·18 November 2014 ·consulta-vinculante Medium impact
Tax

Share exchange in Spanish society via Dutch STAK may be subject to IRPNR and ITP/AJD

A Belgian resident couple asks whether exchanging shares in a Spanish company for certificates of a Dutch STAK has tax implications. The DGT states the transaction may be subject to IRPNR on patrimonial gain and ITP/AJD due to the STAK's acquisition of shares.

In 6 key points

How it affects those involved

The share exchange may trigger IRPNR on patrimonial gain and ITP/AJD due to the STAK's acquisition of shares.

Lifecycle

2014-11-18PublishedPublished 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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