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Four brothers ask whether contributing their shares in a holding company to new individual companies meets the conditions for applying the special regime under LIS. The DGT states that if the conditions of ownership and participation are met, the transaction could qualify for the regime, provided the economic motives are valid.
Question posed: Confirmation that the contributions of PF1, PF2, PF3, and PF4 of the shares held in entity A in favor of, each of them, a newly created entity (N1, N2, N3, and N4, respectively), comply with all the requirements provided for in Article 87.1 of the LIS so that the special tax regime established in Chapter VII of Title VII of the same legal text is applicable to them.
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