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An entity has queried whether a contribution of shares can qualify for the special regime under the Corporate Income Tax Act (LIS) and how to calculate indirect participation. The DGT has ruled that this is possible provided that the shareholding percentage requirements are met and valid economic reasons exist, noting that indirect participation must be calculated on an aggregate basis for the tax group.
Question raised 1) Whether the described non-monetary contribution operations may qualify for the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Value Added Tax.
Para aplicar el régimen especial de aportaciones no dinerarias, el aportante debe poseer al menos el 5% de los fondos propios de la entidad receptora y haber mantenido dicha participación ininterrumpidamente durante el año anterior. La operación no debe tener como objetivo principal el fraude o la evasión fiscal, requiriendo motivos económicos válidos. El requisito de participación indirecta del 5% debe calcularse teniendo en cuenta los porcentajes de participación de todas las entidades que forman parte del grupo fiscal.
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