In the issuance of new shares, you will need to take into account the pre-emption rights of other shareholders (the right of existing shareholders to purchase a share with priority). The shares must, therefore, be offered to them first.
Only a transfer generally has no tax consequences for the B.V. (private limited company). A B.V. cannot hold shares in itself, so a transfer will always take place between, for example, Jan and Piet. If shares are issued at a higher amount than the nominal value, a fiscal reserve (additional paid-in capital or agio reserve) is created for the B.V. If the entire issuance is distributed pro rata among the existing shareholders, for example, with the aim of keeping an individual share affordable (splitting), this has no tax consequences for the B.V.