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A natural person enquires whether contributing their shares in a holding company to another company may qualify for the special tax regime. The DGT responds that this is possible if the required shareholding percentages are met and the transaction has valid economic motives.
Question posed: Whether the described transaction may qualify for the special tax regime under Chapter VII of Title VII of Corporate Income Tax Law 27/2014, of November 27.
In order for the contribution of shares or social interests by natural persons to qualify for the special regime, these must represent at least 5% of the entity's equity and must have been held uninterruptedly during the previous year. Furthermore, following the contribution, the contributor must maintain a holding of at least 5% of the equity of the receiving entity. The transaction must not have the primary objective of tax fraud or evasion, and must respond to valid economic reasons such as the restructuring or rationalization of activities.
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