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A natural person enquires whether the special regime for non-cash contributions can be applied in a reorganisation of their shareholding in a holding company. The DGT states that it applies if participation and ownership requirements are met and the transaction has valid economic reasons.
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 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 be subject to the AIE or UTE regime, nor have the management of movable or immovable property as its main activity. The transaction must not have the primary objective of tax fraud or evasion, and must respond to valid economic reasons rather than a mere pursuit of tax advantage.
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