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A taxpayer has enquired whether the creation of a holding company through the exchange of interests and the contribution of shares from other companies may qualify for the special regime under the Corporate Income Tax Act (LIS). The Directorate General for Taxes (DGT) responds that this is possible provided that the requirements for residence, minimum shareholding, and uninterrupted ownership are met, and that the transaction is supported by valid economic reasons.
Question posed: Whether the described operations may qualify for the special tax regime under Chapter VII of Title VII of the Corporate Income Tax Law 27/2014, of November 27.
For the exchange of securities, the acquiring entity must obtain the majority of voting rights and comply with the residence and tax valuation requirements of Article 80.1 of the Corporate Income Tax Act. Regarding non-monetary contributions of equity interests, it is required that they represent at least 5% of the equity, that they have been held uninterruptedly during the previous year, and that the contributor maintains at least a 5% stake in the receiving entity. Finally, the transaction must not have the primary objective of tax fraud or evasion, and must respond to valid economic reasons such as the restructuring or rationalization of activities.
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