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A US company asks whether exchanging its LLC shares for Irish company shares creates a taxable event in Spain, and whether relocating the LLC to Spain triggers taxable income. The DGT confirms that the share exchange is not taxable under the US-Spain double taxation treaty and that moving the company's domicile to Spain does not generate taxable income.
Question raised 1. Transfer of the LLC Company to the Irish Company
Income from the exchange of securities is classified as a capital gain under the Convention between Spain and the USA. If the transferred shares do not correspond to entities whose assets consist primarily of real estate in Spain, nor grant rights of enjoyment over them, taxation may only be carried out in the State of residence of the transferor (USA). Likewise, the transfer of the registered office of the LLC to Spain through transformation into a limited liability company does not generate taxable income for the company or for its partners.
What is published here, applied to a company or a specific case. The first meeting is free.
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