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A natural person asks whether transferring shares between entities can qualify for the special LIS regime. The DGT states that this is possible if the participation and ownership requirements are met, and if the transaction has valid economic motives rather than merely tax advantages.
Question raised 1. Whether the share contribution transactions proposed in the consultation request 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 and whether valid economic reasons exist.
To apply the special regime for non-monetary contributions, the receiving entity must be a resident in Spain, the contributor must retain at least 5% of their equity following the transaction, and the shares must have been held uninterruptedly during the previous year. Furthermore, the transaction must not have the primary objective of tax fraud or evasion, but rather valid economic reasons. The classification of the entity's activity as management of movable or immovable property will depend on the existence of a sufficient organization of material and human resources for the management of the shares.
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