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A family group has enquired whether the contribution of shares from a community of property to new companies, followed by a share exchange, can qualify for the special regime under the Corporate Income Tax Act (LIS). The Directorate General for Taxes (DGT) has ruled that this is possible provided that the requirements regarding participation and economic activity are satisfied, and that the proposed restructuring reasons are economically valid.
Question raised: Whether the projected operation meets the requirements for the application of the special regime of Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax. In particular, whether it can be understood to be carried out for valid economic reasons.
The contribution of a co-owner's ideal share is considered a special non-monetary contribution subject to the regime of Article 87.1 of the LIS, provided that the minimum participation of 5% is met and the elements are used for economic activities with commercial accounting. The exchange of securities may apply the special regime if the beneficiary company acquires the majority of voting rights and the requirements of Article 80 of the LIS are met. The reasons of centralization, professionalization, simplification of management, financing, and succession are considered economically valid according to Article 89.2 of the LIS.
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