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A natural person enquires whether the special regime for asset contributions can be applied in a restructure of their stake in a holding company. The DGT states that it applies if participation, uninterrupted ownership and entity activity requirements are met, provided the transaction has valid economic grounds and is not solely for tax advantages.
Question posed: Whether it is possible to apply to the proposed restructuring operation the special tax regime regulated in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
The special regime for contributions of assets is applicable if the receiving entity is resident in Spain, the contributor retains at least 5% of the equity following the transaction, and the shares have been held uninterruptedly during the previous year. Furthermore, the contributed entity must not have the management of movable or immovable property as its main activity, nor be subject to the regime for groupings of economic interest. The transaction must not have the primary objective of tax fraud or evasion, and must respond to valid economic reasons rather than the mere pursuit of a tax advantage.
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