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A married couple has enquired whether the contribution of shares in several 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) indicates that this regime will apply to entities A, B, and D, provided the shareholding percentage requirements are met; however, it will not apply to entity C, as it fails to reach the 5% individual threshold due to the community property regime.
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 la aportación de acciones o participaciones sociales, se requiere que representen al menos el 5% de los fondos propios de la entidad receptora y que el aportante mantenga dicha participación ininterrumpidamente durante el año anterior. Además, tras la aportación, el aportante debe participar en al menos un 5% de los fondos propios de la entidad receptora. La operación no debe tener como principal objetivo el fraude o la evasión fiscal, sino motivos económicos válidos como la reestructuración o racionalización de actividades.
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