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The applicant asks whether the exemption under Article 21.3 of the Corporate Income Tax Act applies to capital gains arising from the transfer of shares in a company. The DGT rules that the exemption shall apply provided that the shareholding percentage and holding period requirements set out in said article are met.
Question raised 1) Whether the application of the exemption regulated in paragraph 3 of article 21 of Law 27/2014, of November 17, on Corporate Income Tax, to the tax capital gain that could arise from the transfer of shares in S by the consulting entity in favor of the ultimate shareholder.
La exención de la renta positiva obtenida en la transmisión de una participación será aplicable en la medida en que se cumplan los requisitos de porcentaje de participación (mínimo 5% o valor de adquisición superior a 20 millones de euros) y de tenencia ininterrumpida durante el año anterior al día de la transmisión. El cumplimiento de estos requisitos determinará la aplicación de la exención a la plusvalía que pudiera derivarse de la transmisión.
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