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A taxpayer asks whether contributions of shares from a Spanish company to another Spanish resident entity may benefit from the LIS special regime. The DGT states that this is possible if the required shareholding percentages are met and if the transaction has valid economic motives, not merely fiscal ones.
Question posed: Whether it is possible to apply to the described transaction the regime provided for in Chapter VII of Title VII of the Corporate Income Tax Law, regarding the special regime for mergers, demergers, contributions of assets, exchange of securities, and change of registered office of a European Company or a European Cooperative Society from one Member State to another within the European Union.
To apply the special regime for non-monetary contributions, the recipient entity must be a resident in Spain or have a permanent establishment. The contributor must have held the shares uninterruptedly during the previous year and maintain a stake of at least 5% in the recipient entity's equity following the transaction. Furthermore, the transaction must not have the primary objective of tax fraud or evasion, and must respond to valid economic reasons rather than the mere pursuit of a tax advantage.
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