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The query asks whether the 70% income threshold for the exemption from positive income in a non-monetary contribution must be met only in the transfer year or across all years of holding. The DGT responds that the income requirement must be satisfied in each year of ownership.
Question raised 1) Whether the exemption of positive income due to the contribution of shares in C requires verifying compliance with the 70% income percentage established in Article 21.1 a) solely in the fiscal year of the contribution or throughout the entire period of ownership of the participation, year by year, with respect to the amount of consolidated income in each fiscal year.
For the exemption under Article 21 of the LIS, the requirement that the income of the participated entity derives 70% from dividends or income from other entities must be met in each and every fiscal year of ownership. If the holding company condition is only met in certain periods, the exemption shall apply proportionally to the fiscal years in which said requirement is met. In the event that the entity is a parent company of a group, the percentage of income shall be calculated based on the consolidated result.
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