
Pillar Two in Spain: key points on the new Top-up Tax for large groups
The transposition in Spain of Council Directive (EU) 2022/2523 of 15 December 2022, on ensuring a global minimum level of taxation for multinational enterprise groups
The Judgment of the Provincial Court of Barcelona
The judgment of the 15th Section of the Barcelona Provincial Court No. 477/2023, dated November 2, deals with the issue of indirect transfers of shares in a company.
The case involves the restriction of the transferability of the shares of a limited liability company and its possible extension to the disposal of shares representing the capital stock of shareholder companies.
The judgment we are commenting on analyzes a case in which company A sold 100% of the shares of companies B1 to B34 to company C. Later, company C transferred the shares of B1 to B34 to company C1.
With the above transaction, company C1 acquired control of company D, previously owned by B1 to B34.
The main question is whether these transfers – which, according to the plaintiff, were made without the proper corporate authorizations – violate the statutory restrictions of company D, understood as the controlled company.
The challenge of indirect transfers
The term “indirect transfers” refers to those transfers that affect the shares of shareholder companies, which implies, in certain cases, the indirect transfer of the shares subject to restrictions.
Therefore, these types of transfers pose a legal challenge when attempting to extend the restrictions of a company to the transfers of shareholder companies.
In this context, it is discussed whether the legal or statutory provisions limiting the transfer of shares can be applied to transfers of shareholder interests.

The transposition in Spain of Council Directive (EU) 2022/2523 of 15 December 2022, on ensuring a global minimum level of taxation for multinational enterprise groups

In many commercial negotiations, M&A transactions or due diligence processes, the non-disclosure agreement (or NDA) is signed as a preliminary formality. However, its effectiveness depends

When a foreign company wants to operate on a stable basis in Spain, one of the first decisions is choosing the appropriate structure: incorporating a
Your privacy settings
Manage Consent Preferences
Necessary
Analytics
Embedded Videos
Google Fonts
Marketing