Partner-attended · reply within 24 business hours
Corporate transactions, capital markets and strategic deals.
Independent assessment and rigorous valuation of assets and businesses.
Business reinvention, sustainability and wealth management.
Corporate governance, succession and transformation
International tax planning and cross-border structuring.
Regulatory compliance and tax reporting obligations.
Special regimes for individuals and digital assets.
Tax defense and wealth taxes
Corporate immigration, ICT transfers, investor residency, digital nomad and regularisation.
Employment relations, mobility and regulatory protection.
Protection, compliance and digital resilience
Data protection, DPO and AI regulation
Company formation, contracts, shareholder agreements and corporate operations.
Contracts, dismissals, redundancies and labour court representation.
Insolvency proceedings, fresh start, micro-enterprise procedure and dissolution.
Litigation, arbitration, mediation, IP and real estate law.
Accounting, reporting and outsourced financial management.
Entity management, governance and personnel administration.
Incorporation, incentives and business acceleration.
Risk management, continuity and recovery
New guides on the latest Spanish tax and immigration developments.
Practical tools for informed decision-making.
The applicant asks whether they can apply the special tax regime for non-monetary contributions when contributing shares of various entities to a holding company. The DGT rules that this is possible provided that the requirements regarding shareholding percentages, uninterrupted ownership, and valid economic reasons are met.
Question raised: Whether the special tax regime for non-monetary contributions established in Article 87 of Law 27/2014, of November 27, on Corporate Income Tax, would apply to the totality of the non-monetary contributions made by the taxpayer and his three daughters to holding company A, assuming the requirement of valid economic reasons established in Article 89 of the same legal body is met.
Para aplicar el régimen del artículo 87 de la LIS, la entidad beneficiaria debe ser residente en España y el aportante debe mantener una participación de al menos el 5% en sus fondos propios. En el caso de acciones o participaciones sociales, estas deben representar al menos el 5% de los fondos propios de la entidad aportada, no ser una gestión de patrimonio mobiliario/inmobiliario y haberse poseído ininterrumpidamente durante el año anterior. Además, la operación debe responder a motivos económicos válidos y no tener como principal objetivo el fraude o la evasión fiscal.
What is published here, applied to a company or a specific case. The first meeting is free.
Partner-attended · reply within 24 business hours
Quick message
We reply within 24 business hours. Confidential handling guaranteed.
Google Meet
Direct slot with the partner. Complimentary consultation · no commitment · cancel up to 24h in advance.
Loading availability…
We're fully booked for the next 14 days.
That's a good sign, and we won't leave you hanging.
Request callback
Tell us a time window and a phone number. A partner will call you back during the chosen slot.
< 24 h reply · direct with partner
Have a specific question? Tell us your situation in a sentence or two: a partner will reply within 24 business hours.
Complimentary 30-minute meeting with the partner responsible for your area. Google Meet or in person. Cancel up to 24h in advance.
Loading availability…
We're fully booked for the next 14 days.
That's a good sign, and we won't leave you hanging.
Tell us your preferred time slot and a phone number. A partner will call you back, with no hold queues and no gatekeepers.
We use our own and third-party cookies to improve your experience. More information
Essential for the website to function. Cannot be disabled.
Help us understand how you use the site to improve it.
Enable relevant content and advertising.