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A natural person enquires whether transferring shares between entities may qualify for the LIS special regime. The DGT states that this is possible if the required shareholding percentages are met and the transaction has valid economic motives, not merely fiscal ones.
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.
In order for the contribution of shares or interests to qualify for the special regime under Article 87 of the LIS, the receiving entity must be a resident in Spain or have a permanent establishment, and the contributor must maintain a holding of at least 5% of the equity of the receiving entity. Furthermore, the contributed interests must represent at least 5% of the equity of the transferring entity and must have been held uninterruptedly during the previous year. Finally, the transaction must not have the primary objective of tax fraud or evasion, and must correspond to valid economic reasons pursuant to Article 89.2 of the LIS.
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