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A company is 50% owned by two natural persons intending to contribute their shares to new holding companies. The DGT states that the transaction may qualify for the special LIS regime if residence, ownership percentage, and uninterrupted ownership criteria are met, subject to the economic motives being grounded in factual reality.
Question posed: Whether the described transaction can 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 holdings must represent at least 5% of the recipient entity's equity, the entity's main activity cannot be the management of movable or immovable property, and the contributor must have held the holdings uninterruptedly during the previous year. The application of the regime is excluded if the main objective of the transaction is tax fraud or evasion, or if it lacks valid economic reasons. Reasons such as succession, management autonomy, or separation of assets could be valid, but their classification depends on the verification of the facts.
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