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The consultant asks whether contributions of shares in a company to a new holding may qualify under the special regime. The DGT responds that this is possible if participation and ownership requirements are met and the transaction has valid economic motives.
Question posed: Whether the described transaction may qualify for the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
In order for the contribution of shares or social interests to qualify for the special regime under Article 87 of the LIS, the receiving entity must be a resident in Spain and the contributor must maintain a holding of at least 5% of its equity following the transaction. Furthermore, the interests must represent at least 5% of the equity of the contributed entity and must have been held uninterruptedly during the previous year. The transaction must not have the primary objective of tax fraud or evasion, and must respond to valid economic motives such as generational succession planning or the rationalization of activities.
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