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The taxpayer asks whether the donation of shares from her parents meets the requirements for the 95% reduction in Inheritance and Gift Tax (ISD), and whether contributing those shares to a holding company violates the obligation to maintain the acquired assets. The Directorate General for Tax (DGT) rules that the age and management function requirements are met, and that contributing to a holding company does not breach the maintenance requirement, provided that the value and the right to Wealth Tax exemptions are preserved.
This ruling provides legal certainty for taxpayers planning to restructure family businesses through holding companies without losing the significant tax benefits associated with inheritance and gift tax reductions.
The tax team reviews your specific situation.
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