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V3557-15 ·17 November 2015 ·consulta-vinculante Medium impact
FISCAL

Conversion of a Dutch CV to an open CV does not generate taxable income or constitute an ERAR

A Spanish resident entity inquired whether converting a Dutch CV into an open CV generates a taxable event and whether the resulting entity would be considered an entity under the Spanish attribution regime (ERAR). The DGT concluded that the operation does not generate taxable income and that the open CV is not analogous to Spanish ERARs.

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2015-11-17PublishedPublished 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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