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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.
Cuestión planteada Confirmación de que las aportaciones de PF1, PF2, PF3 y PF4 de las participaciones que ostentan en la entidad A a favor, cada uno de ellos, de una entidad de nueva creación (N1, N2, N3 y N4, respectivamente), cumplen todos los requisitos previstos en el artículo 87.1 de la LIS para que les resulte de aplicación el régimen fiscal especial establecido en el Capítulo VII del Título VII del mismo texto legal.
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