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V3540-19 ·26 December 2019 ·consulta-vinculante Medium impact
Tax

Non-monetary contributions may apply under special regime if participation and economic motives are met

A Spanish resident asks whether transferring their shares in company A to a new company B qualifies for the special regime. The DGT confirms this is possible if the participation percentage and uninterrupted ownership requirements are met, provided the transfer has valid economic motives.

In 6 key points

How it affects those involved

The guidance clarifies conditions under which non-monetary share transfers in reorganisations may qualify for a special regime, ensuring alignment with economic rationale and ownership continuity.

Lifecycle

2019-12-26PublishedPublished 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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