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V3120-23 ·1 December 2023 ·consulta-vinculante Medium impact
Tax

Fiscal neutrality possible for share transfers to holding company

A physical person asks whether transferring shares to a holding company may qualify for fiscal neutrality. The DGT confirms this is possible if minimum 5% ownership, holding duration, and the receiving entity not managing movable or immovable assets are met.

In 6 key points

How it affects those involved

Share transfers to holding companies may qualify for fiscal neutrality under specific conditions.

Lifecycle

2023-12-01PublishedPublished 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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