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A natural person asks whether transferring their shares in entity A to society B qualifies for the special non-cash contribution regime. The DGT states that the conditions are met if the receiving entity is resident, the contributor holds more than 5% shareholding, and the transferred entity is not a movable or immovable property management fund.
Question posed: Whether the contribution by the taxpayer of the shares of entity A to company B meets the legally provided requirements to qualify for the tax mechanism of non-monetary contribution provided for in Article 87.1 of Chapter VII of Title VII of the Corporate Income Tax Law.
To apply the special regime for non-monetary contributions, the recipient entity must be a resident in Spain and the contributor must retain at least 5% of the entity's equity following the transaction. The contributed entity may not be an economic interest group nor have the management of movable or immovable property as its primary activity. Furthermore, the transaction must respond to valid economic reasons and not have the primary purpose of obtaining a tax advantage. The DGT does not issue a ruling on the exemption for the transfer of shares due to the unknown timing of the future transaction.
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