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A taxpayer asks whether they can contribute both full and bare ownership of shares in a holding company to a new entity without tax. The DGT responds that the status of shareholder rests with the bare owner and that the transaction may qualify under the non-monetary contributions regime if legal requirements are met.
Cuestión planteada 1. Confirmación de que la operación de reestructuración planteada cumple todos los requisitos previstos legalmente para acogerse a la figura de las aportaciones no dinerarias prevista en el artículo 87.1 de la LIS, así como si los motivos económicos alegados son considerados como válidos a efectos de la aplicación del régimen de neutralidad fiscal previsto en el Capítulo VII del Título VII de la LIS.
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