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A consultant asks whether contributions of shares from an entity to new holding companies may qualify for the LIS special regime. The DGT states that this is possible if the percentage of ownership and uninterrupted holding are met, provided the transaction has valid economic motives and is not solely for tax advantages.
Question posed: Whether the described transaction 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.
To apply the special regime under Article 87 of the LIS, the contributed shares must represent at least 5% of the equity and must have been held uninterruptedly during the previous year. Furthermore, the transaction must not have the primary objective of tax fraud or evasion, requiring valid economic reasons pursuant to Article 89.2 of the LIS. Reasons concerning the rationalization of wealth management and family succession could be considered valid, although their classification depends on the actual facts.
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