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A family group has enquired whether the contribution of shares from various companies to a new holding company can qualify for the special regime under the Corporate Income Tax Act (LIS). The Directorate General for Taxes (DGT) responds that this is possible, provided that requirements regarding voting rights majorities, shareholding percentages, and valid economic reasons are met.
Question raised: Whether the described operation 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 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. Para las aportaciones no dinerarias, las participaciones deben representar al menos el 5% de los fondos propios y haber sido poseídas ininterrumpidamente durante el año anterior. La operación no podrá acogerse al régimen si su objetivo principal es el fraude o la evasión fiscal, debiendo existir motivos económicos válidos como la reestructuración o racionalización de actividades.
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