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An entity inquires whether the contribution of shares by three individual partners to a new holding company may qualify for the special regime of the CIT Act. The DGT responds that this is possible if the requirements regarding participation and valid economic reasons are met, and that subsequent dividends could be exempt.
Question raised 1) 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.
The contribution of shares may qualify for the special regime under Article 87 of the CIT Act if the contributors hold at least 5% of the equity of the receiving entity and maintain said participation following the transaction. To avoid the application of Article 89.2, the transaction must respond to valid economic reasons and not to a mere tax advantage. Likewise, dividends distributed by the inquiring company may be exempt under Article 21 of the CIT Act if the requirements regarding participation and holding are met.
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