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A natural person inquires whether the contribution of shares from several entities to a new company meets the requirements of the special regime under the LIS. The DGT responds that the regime applies if the contributed shares represent at least 5% of the equity and a 5% participation in the receiving entity is achieved, but it does not apply if said threshold is not reached.
Question posed - Whether the non-monetary contribution of the projected shares of CV, B, AR, and PR, in which the natural person PF1 holds at least a 5% interest, complies with the requirements for the application of the Special Tax Regime for mergers, spin-offs, contributions of assets, and exchange of securities under Title VII of Chapter VII of the LIS.
Para aplicar el régimen especial de aportaciones no dinerarias, la entidad receptora debe ser residente en España y el aportante debe participar en sus fondos propios al menos un 5%. En el caso de personas físicas, las participaciones aportadas deben representar al menos el 5% de los fondos propios de la entidad aportada y haber sido poseídas ininterrumpidamente durante el año anterior. Basta con alcanzar el 5% de participación en la entidad receptora tras la operación para cumplir este requisito. Si no se alcanza el umbral del 5% en las entidades aportadas, no se aplica la neutralidad fiscal.
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