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The query asks whether deferred gains from a previous transfer are exempt in a new transfer if the conditions in article 21.4.a) of the LIS are not met. The DGT responds that such gains are exempt if all requirements of article 21 of the LIS are satisfied.
Question posed: If assumptions 1st and 2nd of article 21.4.a) of the Corporate Income Tax Law are not met, would the deferred income not integrated into the previous contribution be exempt in the subsequent transfer of the holdings?
If neither assumptions 1st nor 2nd of article 21.4.a) of the LIS are met, the income derived from the transfer of the securities portfolio shall be exempt. To this end, it is necessary to comply with all the requirements established in article 21 of the LIS. The DGT does not rule on the economic motivation of the previous operation due to lack of information.
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