Partner-attended · reply within 24 business hours
Corporate transactions, capital markets and strategic deals.
Independent assessment and rigorous valuation of assets and businesses.
Business reinvention, sustainability and wealth management.
Corporate governance, succession and transformation
International tax planning and cross-border structuring.
Regulatory compliance and tax reporting obligations.
Special regimes for individuals and digital assets.
Tax defense and wealth taxes
Corporate immigration, ICT transfers, investor residency, digital nomad and regularisation.
Employment relations, mobility and regulatory protection.
Protection, compliance and digital resilience
Data protection, DPO and AI regulation
Company formation, contracts, shareholder agreements and corporate operations.
Contracts, dismissals, redundancies and labour court representation.
Insolvency proceedings, fresh start, micro-enterprise procedure and dissolution.
Litigation, arbitration, mediation, IP and real estate law.
Accounting, reporting and outsourced financial management.
Entity management, governance and personnel administration.
Incorporation, incentives and business acceleration.
Risk management, continuity and recovery
New guides on the latest Spanish tax and immigration developments.
Practical tools for informed decision-making.
The query asks whether a non-monetary contribution of shares can qualify for the special regime under the Corporate Income Tax Act (LIS), even if a voting syndicate agreement reduces voting rights to below 50%. The DGT rules that this is possible provided that the requirements regarding participation and valid economic reasons are met.
Question raised: Whether the aforementioned non-monetary contribution would be entitled to the regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax (CIT), falling under the figure of the exchange of securities of article 76.5 of said Law.
La aportación no dineraria puede aplicar el régimen especial del Capítulo VII del Título VII de la LIS si la entidad receptora es residente en España y el aportante mantiene una participación de al menos el 5% en los fondos propios. En el caso de personas físicas, las acciones deben representar al menos el 5% de los fondos propios y haber sido poseídas ininterrumpidamente durante el año anterior. La operación no debe tener como principal objetivo el fraude o la evasión fiscal, sino motivos económicos válidos.
What is published here, applied to a company or a specific case. The first meeting is free.
Partner-attended · reply within 24 business hours
Quick message
We reply within 24 business hours. Confidential handling guaranteed.
Google Meet
Direct slot with the partner. Complimentary consultation · no commitment · cancel up to 24h in advance.
Loading availability…
We're fully booked for the next 14 days.
That's a good sign, and we won't leave you hanging.
Request callback
Tell us a time window and a phone number. A partner will call you back during the chosen slot.
< 24 h reply · direct with partner
Have a specific question? Tell us your situation in a sentence or two: a partner will reply within 24 business hours.
Complimentary 30-minute meeting with the partner responsible for your area. Google Meet or in person. Cancel up to 24h in advance.
Loading availability…
We're fully booked for the next 14 days.
That's a good sign, and we won't leave you hanging.
Tell us your preferred time slot and a phone number. A partner will call you back, with no hold queues and no gatekeepers.
We use our own and third-party cookies to improve your experience. More information
Essential for the website to function. Cannot be disabled.
Help us understand how you use the site to improve it.
Enable relevant content and advertising.