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Two natural persons (PF1 and PF2), together with their parents, hold shares in four operating entities (A, B, C and D) and plan to transfer their shares to two newly established holding companies (NEWCO1 and NEWCO2). The DGT confirms that the transaction may qualify for the special regime under Chapter VII of Title VII of the LIS (art. 87) if the 5% ownership threshold and uninterrupted holding during the previous year are met. The values received are assessed at the fiscal cost of the shares contributed (arts. 78 and 79 LIS). Dividends distributed by entities A, B, C and D to the NEWCOs may be exempt under article 21 LIS. The patrimonial status of the NEWCOs cannot be determined without sufficient consolidated balance sheet data.
Cuestión planteada 1)Si las operaciones de aportación de las participaciones sociales a las entidades holding pueden acogerse al régimen especial de fusiones, escisiones, aportaciones de activos, previsto en los artículos 76 a 89 de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades (LIS), y si los motivos expuestos tienen la consideración de económicamente válidos a estos efectos.
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