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A tourism group transfers 100% of a Czech subsidiary holding a leased hotel to another group company operating it. The DGT confirms that positive income may be exempt under LIS art. 21 if participation and minimum taxation requirements are met. To assess whether the subsidiary is a patrimonial entity, valuation must be based on the consolidated quarterly balances of the subgroup, in line with consultation V1654-16.
Question raised
The exemption for the transfer of shares under Article 21.3 LIS requires a holding of at least 5% for more than one year and that the subsidiary is subject to a minimum taxation of 10%; in this case, the subsidiary resident in the Czech Republic is covered by the Spanish-Czech DTA with an exchange of information clause. The condition of being a holding company under Article 5.2 LIS must be assessed based on the consolidated quarterly balance sheets of the group of companies acting in a coordinated manner, such that a company holding real estate leased to another operating company within the same group is not considered a holding company if the consolidated accounts reflect economic activity. The exemption applies net of 5% for management expenses pursuant to Article 21.10 LIS.
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