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A query was raised regarding whether the contribution of shares from an entity to newly incorporated companies meets the requirements of the special regime under the Corporate Income Tax Act (LIS). The Directorate General of Taxes (DGT) indicates that this regime is applicable provided that the requirements of residency, a minimum 5% shareholding, and uninterrupted ownership are met, provided there are valid economic reasons.
Question raised: Whether the operation described regarding the contribution of shares to newly incorporated companies, as described, meets the requirements established in Article 87 of Law 27/2014, of November 27.
El régimen especial es aplicable a las aportaciones no dinerarias si la entidad receptora es residente en España, el aportante mantiene al menos un 5% de los fondos propios y posee las participaciones ininterrumpidamente durante el año anterior. No se aplicará el régimen si la operación tiene como principal objetivo el fraude o la evasión fiscal sin motivos económicos válidos. Los motivos de sucesión accionarial y relevo generacional pueden considerarse válidos para evitar la aplicación del artículo 89.2 de la LIS.
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