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The taxpayer asks whether the transfer of a portion of their holding in an entity is exempt if the acquisition cost of the transferred blocks exceeds 20 million euros. The DGT rules that the exemption applies if the acquisition value requirement is met, regardless of the percentage being transferred.
Question raised 1) Whether the transfer mentioned would be exempt if the percentage of interest represented by the transferred shares is less than 5% of their interest in A, but their individual acquisition cost was greater than 20 million euros.
The exemption under Article 21 of the LIS applies if the acquisition value of the interest is greater than 20 million euros or if at least 5% of the capital is held. For the exemption on the transfer, the value or percentage requirement must be met on the date of the transfer. If the entire interest is not transferred, the exemption shall apply to the extent that the individual acquisition cost of each transferred block exceeds 20 million euros. The exempt positive income shall not be limited by the reduction of the tax value due to dividends.
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