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A taxpayer asks whether transferring shares from several entities to a holding company may qualify for the special LIS regime and whether valid economic reasons exist. The DGT states that eligibility depends on whether the transaction is classified as a share exchange or a non-cash contribution, based on the voting rights acquired.
Cuestión planteada Si a la aportación no dineraria de las participaciones a la sociedad Holding por parte del consultante procede la aplicación del régimen fiscal especial previsto en el Capítulo VII del Título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades y si existen motivos económicos válidos.
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