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V3324-23 ·28 December 2023 ·consulta-vinculante Medium impact
Tax

Total split may qualify for tax neutrality if conditions met

A group of brothers asks whether a total split of their company meets the requirements to apply the tax neutrality regime under Corporate Tax and tax deferral under Personal Income Tax. The DGT states that if the operation is carried out commercially in accordance with current regulations and shareholders receive proportional shares, the regime may apply, provided it is not for obtaining tax benefits without economic justification.

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2023-12-28PublishedPublished 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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