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A holding company has inquired whether the contribution of shares in a Portuguese company by its shareholders 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 shareholding, holding period, and corporate purpose are met, and that the transaction is supported by valid economic reasons.
Question raised - Whether the described operation could 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.
Para aplicar el régimen especial del artículo 87 de la LIS, las participaciones aportadas deben representar al menos el 5% de los fondos propios de una entidad que no sea una AIE, UTÉ o de gestión de patrimonio mobiliario/inmobiliario, y haber sido poseídas ininterrumpidamente durante el año anterior. Además, tras la aportación, el aportante debe mantener al menos un 5% de los fondos propios de la entidad receptora. Finalmente, la operación no debe tener como objetivo principal el fraude o la evasión fiscal, debiendo responder a motivos económicos válidos según el artículo 89.2 de la LIS.
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