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A natural person asks whether contributions of shares from two companies to a third can qualify for the special LIS regime. The DGT states that minimum participation and ownership requirements are met, but warns that the validity of economic motives will depend on specific facts and possible buy-sell options.
Question posed: Whether the described transaction may qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax, and whether valid economic reasons exist.
To apply the special regime for non-monetary contributions, the receiving entity must be a resident in Spain and the contributor must hold at least 5% of its equity following the transaction. In the case of natural persons, the holdings must represent at least 5% of the equity of an entity that is not an AIE, a UTÉ, or a real estate/movable property management company, and must have been held uninterruptedly during the previous year. The economic reasons for avoiding the anti-fraud regime must be valid, although the existence of call or put options on the contributed holdings could influence the determination of the main purpose of the transaction.
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