Partner-attended · reply within 24 business hours
Corporate transactions, capital markets and strategic deals.
Independent assessment and rigorous valuation of assets and businesses.
Business reinvention, sustainability and wealth management.
Corporate governance, succession and transformation
International tax planning and cross-border structuring.
Regulatory compliance and tax reporting obligations.
Special regimes for individuals and digital assets.
Tax defense and wealth taxes
Corporate immigration, ICT transfers, investor residency, digital nomad and regularisation.
Employment relations, mobility and regulatory protection.
Protection, compliance and digital resilience
Data protection, DPO and AI regulation
Company formation, contracts, shareholder agreements and corporate operations.
Contracts, dismissals, redundancies and labour court representation.
Insolvency proceedings, fresh start, micro-enterprise procedure and dissolution.
Litigation, arbitration, mediation, IP and real estate law.
Accounting, reporting and outsourced financial management.
Entity management, governance and personnel administration.
Incorporation, incentives and business acceleration.
Risk management, continuity and recovery
New guides on the latest Spanish tax and immigration developments.
Practical tools for informed decision-making.
A natural person inquires whether the contribution of their shares in entity A to entity B may apply the special regime for mergers and demergers. The DGT indicates that this is possible if the requirements of minimum participation, residence, and uninterrupted ownership are met, provided it is not for the purpose of tax fraud or evasion.
Question posed: Whether the special regime for mergers, demergers, contributions of assets, exchange of securities, and change of registered office of a European company or European cooperative society from one Member State to another of the European Union, as enshrined in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax, is applicable to the proposed business restructuring operation.
To apply the tax neutrality regime in non-monetary contributions, the receiving entity must be resident in Spain or have a permanent establishment. The contributor must have held the shares uninterruptedly during the previous year and maintain a participation of at least 5% in the equity of the receiving entity following the transaction. The regime shall not apply if the primary objective is to obtain a tax advantage without valid economic reasons.
Partner-attended · reply within 24 business hours
Quick message
We reply within 24 business hours. Confidential handling guaranteed.
Google Meet
Direct slot with the partner. Complimentary consultation · no commitment · cancel up to 24h in advance.
Loading availability…
We're fully booked for the next 14 days.
That's a good sign — and we won't leave you hanging.
Request callback
Tell us a time window and a phone number. A partner will call you back during the chosen slot.
< 24 h reply · direct with partner
Have a specific question? Tell us your situation in a sentence or two — a partner will reply within 24 business hours.
Complimentary 30-minute meeting with the partner responsible for your area. Google Meet or in person. Cancel up to 24h in advance.
Loading availability…
We're fully booked for the next 14 days.
That's a good sign — and we won't leave you hanging.
Tell us your preferred time slot and a phone number. A partner will call you back — no hold queues, no gatekeepers.
We use our own and third-party cookies to improve your experience. More information
Essential for the website to function. Cannot be disabled.
Help us understand how you use the site to improve it.
Enable relevant content and advertising.