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A married couple has enquired whether the contribution of shares from transformed companies (from SAT to SL) to a new holding company can qualify for the special regime under the Corporate Income Tax Act (LIS). The Directorate General for Taxes (DGT) indicates that this is possible provided that the requirements regarding residency, minimum shareholding, and tenure are met, and as long as there is no tax fraud or evasion.
Question raised: Whether the described operations may qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax and whether valid economic reasons exist.
Para aplicar el régimen especial de aportaciones no dinerarias, la entidad receptora debe residir en España y el aportante debe mantener al menos un 5% de los fondos propios. La antigüedad de las participaciones en la sociedad resultante se computa desde la adquisición original en la sociedad agraria de transformación, ya que la transformación no altera la personalidad jurídica. Además, la operación debe responder a motivos económicos válidos y no tener como fin principal la obtención de una ventaja fiscal.
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