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An individual is inquiring whether the contribution of their shares in a company to a new holding company (NEWCO) can qualify for the special Corporate Tax regime. The DGT indicates that this is possible provided that the shareholding percentage requirements are met and the transaction is supported by valid economic reasons.
Question raised 1) Whether the described operation could qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
Para aplicar el régimen especial de aportaciones no dinerarias, la entidad receptora debe ser residente en España y el aportante debe participar en sus fondos propios al menos un 5%. Además, las participaciones aportadas deben haber sido poseídas ininterrumpidamente durante el año anterior y la entidad no puede tener como actividad principal la gestión de patrimonio mobiliario o inmobiliario. La operación no debe tener como objetivo principal el fraude o la evasión fiscal, requiriendo motivos económicos válidos.
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