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A query was raised regarding whether a contribution of activity and an exchange of social shares could qualify for the special regime under the TRLIS, and whether subsequent donations of shares would benefit from reductions in Inheritance and Gift Tax (ISD). The Directorate-General for Taxes (DGT) ruled that the requirements for the special regime for contributions are met and that donations could qualify for a 95% reduction, provided the conditions of Law 29/1987 are satisfied.
This ruling clarifies the tax treatment for corporate restructuring involving non-monetary contributions and share exchanges, confirming eligibility for special tax regimes and potential significant reductions in gift tax for subsequent share transfers.
The tax team reviews your specific situation.
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