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The consultant asks whether a reorganisation transaction creating a holding company may qualify for the special regime under the LIS. The DGT states that this will depend on whether the conditions for share exchange or non-cash contributions are met and that the transaction is not primarily aimed at obtaining a fiscal advantage.
Question raised: 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.
For the exchange of securities, the entity must acquire the majority of voting rights and comply with the requirements of Article 80 of the LIS. For non-monetary contributions, Article 87 of the LIS must be met, including the minimum 5% participation in equity. The application of the special regime is excluded if the main purpose of the transaction is tax fraud or evasion, or if it lacks valid economic reasons according to Article 89.2 of the LIS. A subsequent donation of shares could influence the determination of the main purpose of the transaction.
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