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V2472-19 ·16 September 2019 ·consulta-vinculante Medium impact
Tax

Non-monetary contributions may apply under special regime if participation and economic motives are met

Consultants ask whether transferring shares from one entity to three others (A, B and C) can qualify for the LIS special regime. The DGT states that this is possible if participation percentages, uninterrupted ownership and valid economic motives are satisfied.

In 6 key points

How it affects those involved

The guidance clarifies conditions under which non-monetary share transfers can qualify for the special LIS regime, supporting restructurings with economic rationale.

Lifecycle

2019-09-16PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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