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A natural person asks whether contributions of their holdings in a holding company to a new company (Newco) may qualify for the special regime. The DGT states that this is possible if participation and ownership requirements are met, provided the transaction has valid economic motives and is not solely for tax advantages.
Question raised: Whether the operation through which the individual consultant would contribute the shareholding currently held in entity A to the company Newco complies with the requirements of article 87 of the Corporate Income Tax Law.
To apply the special regime of art. 87 LIS, the receiving entity must be a resident in Spain and the contributor must hold at least 5% of its equity. In the case of a contribution of shares, these must represent at least 5% of the equity of the contributed entity, must have been held uninterruptedly during the previous year, and the contributed entity cannot have the management of movable or immovable property as its main activity. Furthermore, the operation must not have the main objective of tax fraud or evasion, and must respond to valid economic reasons according to art. 89.2 LIS.
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