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Participaciones Sociales — evolución doctrinal DGT
evolution::participaciones-sociales
Deduction for investment available in newly established companies across consecutive years
V5344-26
Gain from share sales can be imputed proportionally if payment period exceeds one year
V5353-26
Price of share sales can be estimated to calculate capital gain
V1642-26
Transmitted share value may be the higher of net worth or market capitalisation
V1419-26
Loss of donation reduction if entity ceases economic activity
V5011-26
Share donations not covered by tax neutrality; property rental may be economic activity
V1092-26
Transfer of shareholdings may be VAT-exempt if it involves transfer of an autonomous economic unit
V1033-26
Public listing of a free purchase option not subject to AJD or onerous transfers tax
V0805-26
Legacies received by a company must be valued at market value and included in its corporate tax base
V0767-26
Free usufruct on shareholdings presumed remunerated for income tax
V0437-26
Reduction in Inheritance Tax requires prior exemption in Wealth Tax
V0356-26
Requirements for 95% tax reduction on succession and donations from social shares donation
V0109-26
Replacement of shares with shares having different economic rights generates taxable income in the taxable base
V2319-25
Dividends from share transfers may qualify for wealth tax exemption
V2218-25
Requirements for the application of the 95% reduction on the donation of social shares
V2220-25
Requirements for the application of the 95% reduction on the donation of social shares (Art. 20.6 LISD)
V1595-25
Requirements for the 95% reduction on the donation of social shares (Art. 20.6 LISD)
V1528-25
Impuesto sobre Sucesiones can be included in acquisition value of inherited shares
V1444-25
Free creation of a life-term usufruct over shareholdings deemed capital movable income
V1320-25
Requirements for patrimony tax exemption via Cyprus holding shares
V1300-25
Dividends received by a shareholder are considered capital gains for income tax
V1277-25
Each real estate society must have a full-time employee for exemption
V1184-25
Possible absence of patrimonial gain or loss in share donation under ISD Art. 20.6
V1044-25
IRPF paid on share transfer not a inherent cost of acquiring shares
V1073-25
No capital gain or loss on share donation if article 20.6 of the ISD law is met
V0895-25
Exercise of a share sale option may be treated as income from work and capital gain
V0789-25
Non-residents may opt for regional regulations where shareholdings were located
V0627-25
Donor must hold shares for 10 years to qualify for IRPF exemption
V0446-25
Free life usufruct on shareholdings deemed capital mobile income
V0447-25
Gain from sale of social shares can be imputed as payments are received
V0270-25
Profit from patrimony absence in IRPF depends on ISD reduction requirements
V0274-25
The legal non-existence of the 'trust' in Spain determines the tax treatment of its contributions and income
V0022-25
Deduction for investment available for newly established companies
V1297-24
Acquisition value of shares in patrimonial companies includes undistributed profits
V1105-24
Requirements for claiming special tax neutrality in social share contributions
V0802-24
Non-cash share contributions may qualify for fiscal neutrality under certain conditions
V0738-24
Requirements for applying fiscal neutrality in social share contributions
V0731-24
Possibility of applying fiscal neutrality to social share contributions to a new entity
V0529-24
Possibility of applying fiscal neutrality to share contributions to a new company
V0531-24
Fiscal neutrality applicable to share swaps and non-cash contributions if legal requirements met
V0484-24
Share contribution to a holding company may qualify for fiscal neutrality under certain conditions
V0430-24
A financial split may qualify for special regime if it meets commercial requirements and retains a business line or majority shares
V0111-24
Fiscal neutrality regime applicable to share swaps and non-cash contributions if legal requirements met
V0020-24
Fiscal neutrality regime applicable to social share contributions if legal requirements met
V3315-23
Financial spin-off may qualify for fiscal neutrality if commercial and ownership requirements are met
V3199-23
Share contributions may qualify for fiscal neutrality if LIS requirements are met
V3140-23
Fiscal neutrality applicable to non-monetary share contributions to a new entity
V3138-23
Requirements for applying the fiscal neutrality regime in non-cash share contributions
V3099-23
Requirements for applying the fiscal neutrality regime to non-monetary share contributions
V2818-23
Requirements for claiming fiscal neutrality in social share contributions
V2730-23
V2699-23
Shareholding contributions to a new company may qualify for fiscal neutrality under certain conditions
V2663-23
V2656-23
Fiscal neutrality regime applicable to social share contributions if conditions met
V2576-23
Full and bare ownership of shares may qualify for fiscal neutrality
V2389-23
V2360-23
Possibility of applying fiscal neutrality regime to non-monetary share contributions
V2361-23
Share contributions may qualify for fiscal neutrality under certain conditions
V2343-23
Possibility of applying fiscal neutrality to non-monetary share contributions
V2339-23
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