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A couple asks whether transferring their shares in three companies to a new holding company qualifies for the LIS special regime. The DGT states that eligibility is only possible where shareholding exceeds 5%, and the economic justification will be verified.
Question posed: Whether the described operation may qualify for the 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 contribution must represent at least 5% of the entity's equity and the contributor must maintain at least 5% in the recipient entity. In this case, the contribution from entity C does not qualify for the regime as it does not reach said 5% threshold. Furthermore, the application of the regime is conditional upon the operation not having tax advantage as its primary objective, but rather valid economic reasons which must be verified.
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