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An individual is inquiring whether the contribution of various shares from different companies to a holding company may qualify for the special regime under the Corporate Income Tax Act. The DGT rules that this is possible provided that the requirements regarding the majority of voting rights for the exchange are met, as well as the requirements concerning shareholding and ownership percentages for non-monetary contributions, provided that valid economic reasons exist.
Question raised: Whether the described operations meet the necessary requirements for the application of the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
Para el canje de valores, la entidad debe adquirir participaciones que le permitan obtener la mayoría de derechos de voto y cumplir el artículo 80 de la LIS. En las aportaciones no dinerarias, las participaciones deben representar al menos el 5% de los fondos propios de la entidad aportada, haber sido poseídas ininterrumpidamente durante el año anterior y el aportante debe mantener al menos un 5% de los fondos propios de la entidad receptora. Estas operaciones deben responder a motivos económicos válidos y no tener como fin principal el fraude o la evasión fiscal.
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