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An entity inquired whether the sale of a 20% shareholding in a Spanish company would generate a full exemption due to already holding 5% for more than one year. The DGT responds that the exemption applies if the minimum percentage or the required acquisition value is met at the time of the transfer.
Question raised 1) Whether the current sale of a 20% shareholding in the share capital of A would determine a full exemption due to already holding at least 5% for more than one year.
To apply the exemption on the transfer of a shareholding, one must hold at least a 5% direct or indirect shareholding at the time of sale, or the acquisition value must exceed 20 million euros. Transferred shares are considered acquired under the FIFO criterion. In this case, as the requirements of Article 21 LIS are met, the transferred shareholding shall apply the exemption regime.
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