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A family group asks whether transferring full and bare ownership of shareholdings to new holding companies qualifies for the LIS special regime. The DGT states this is possible provided participation, uninterrupted possession, and no primary fiscal advantage are met.
Question posed: Whether the contributions described in this ruling made by PF1, PF2, and PF3 of the full ownership, bare ownership, and usufruct of the shares in Company X meet all the requirements provided for in Article 87.1 of the LIS so that the special tax regime established in Chapter VII of Title VII of the LIS applies to them. And whether the economic reasons set forth can be deemed valid according to the provisions of Article 89.2 of the LIS.
Contributions of full ownership and bare ownership of shares may qualify for the special regime under Article 87 of the LIS if the requirements regarding the residence of the receiving entity, a minimum equity participation of 5%, and uninterrupted ownership during the previous year are met. In the case of usufruct, the principle of neutrality allows the usufructuary not to recognize income if the right retains its economic rights following the substitution of the shares. However, the application of the regime is excluded if the primary objective of the transaction is tax fraud or evasion, or if it is not carried out for valid economic reasons pursuant to Article 89.2 of the LIS.
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