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V0989-14 7 April 2014 · SG de Fiscalidad Internacional Criterion in force
IRNR · trust

Dissolution of a foreign trust does not trigger Spanish taxation

A company incorporated in Guernsey, holding shares owned by a UK trust, asks whether the dissolution of the trust, transferring ownership to beneficiaries in Germany, triggers Spanish tax. The DGT responds that the dissolution of this trust does not generate Spanish tax.

The question raised

Whether the dissolution of the trust, whereby the formal ownership held by B and C of the consulting company A passes to natural persons resident in Germany, is subject to taxation in Spain.

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