Skip to content
V4320-16 ·6 October 2016 ·consulta-vinculante Medium impact
FISCAL

Possibility of maintaining group entity special regime after share swap with foreign subsidiary

A dominant entity plans to establish a UK subsidiary via a share swap, transferring 100% of its current subsidiary holdings. Tax authorities state the dominant entity may continue applying the special group regime if it maintains indirect control exceeding 50%.

In 6 key points

How it affects those involved

The regime allows dominant entities to retain special tax treatment under certain conditions following a share swap with a foreign subsidiary.

Lifecycle

2016-10-06PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

Does this provision affect you?

The fiscal team reviews your specific situation.

Talk to the fiscal team
This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
Email
Contact