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A natural person asks whether contributions of shares in a holding company to a new company (NEWCO) may qualify for the special IS regime. The DGT states that this is possible if the percentage of ownership requirements are met and the transaction is based on valid economic grounds, not merely tax advantages.
Question raised 1) Whether the described transaction 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.
To apply the special regime under Article 87 of the LIS, the receiving entity must be a resident in Spain and the contributor must hold at least 5% of the entity's equity following the contribution. Furthermore, the transaction must not have the primary objective of tax fraud or evasion, and must respond to valid economic reasons such as the restructuring or rationalization of activities. Reasons concerning generational succession planning and resource optimization could be considered valid, although their classification depends on the facts.
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