Corporate Reorganizations

Mixed holding and intragroup transfer of participations: differentiated sector under VAT, save autonomous economic unit

The Spanish Supreme Court confirms that intragroup transfers of participations by a mixed holding company are part of the financial differentiated sector for VAT purposes, save where they entail the transfer of an …

The intragroup transfer of participations by a mixed holding company forms a differentiated sector for VAT purposes, save where it entails the transfer of an autonomous economic unit

Family-business exemption: the remuneration received from companies transferred in the framework of a restructuring is excluded from the 50% calculation at the level of the holding company

Restructuring into a holding: the prior remuneration of the subsidiaries does not cloud the 50% of the family business

The DGT confirms that the contribution of subsidiaries to a holding does not break the family-business exemption: the prior remuneration from the transferred subsidiaries is not integrated into the 50% calculation at the …

The total division to facilitate generational handover is a valid economic reason for the purposes of the FEAC regime of the Corporate Income Tax

Total division to prepare generational handover: valid economic reason under the FEAC regime

The DGT confirms that a total division aimed at preparing succession and facilitating generational handover is a valid economic reason under article 89.2 of the LIS and accesses the FEAC regime.