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A Norwegian resident enquires about the tax implications of contributing shares in a Spanish company to form a new entity. The DGT states that as the shareholding is substantial, the gain may be taxable in Spain under the IRNR and examines the possible application of special regimes.
Cuestión planteada El consultante plantea lo siguiente:
Al tratarse de una participación sustancial (superior al 25%), la potestad tributaria puede recaer en España según el Convenio Hispano-Noruego. La ganancia estará sujeta al IRNR salvo que se cumplan condiciones de exención. Asimismo, el sujeto pasivo podría aplicar el régimen especial de aportaciones no dinerarias del TRLIS si cumple los requisitos de participación y motivación económica válida.
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