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A natural person asks whether contributing shares from a company to a new holding company qualifies for the special regime of non-cash contributions. The DGT responds that it is possible if the beneficiary entity is resident in Spain, participation and ownership requirements are met, and the transaction is based on valid economic reasons rather than solely tax advantages.
Cuestión planteada Si la operación planteada podría acogerse al régimen fiscal especial regulado en el capítulo VII del título VII de la Ley del Impuesto sobre Sociedades. Y si los motivos económicos pueden considerarse como válidos a efectos de la aplicación del citado régimen especial.
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