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A company enquired whether its non-monetary contribution of shares could qualify for the special tax regime for business reorganisations. The DGT indicates that, provided certain residency and shareholding requirements are met, the transaction may qualify for this regime, provided its primary purpose is not tax evasion or obtaining an unfair tax advantage.
Question raised: It is asked whether the described non-monetary contribution transaction could qualify for the special tax regime regulated in Chapter VIII of Title VII of the TRLIS.
The transaction could qualify for the special regime under Chapter VIII of Title VII of the TRLIS if the residency requirements of the recipient entity are met and the contributor holds a minimum stake of five percent in the equity. However, the regime shall not apply if the primary objective is fraud, evasion, or the mere obtaining of a tax advantage without valid economic reasons. In this instance, the purpose of preventing the dilution of minority shareholders may be considered a valid economic reason.
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