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Some shareholders inquire whether contributions of shares in one entity to another can qualify for the special merger and asset contribution regime. The DGT confirms this is possible provided the requirements relating to shareholding, residence and activity are met, and the transaction has genuine economic motives rather than purely fiscal ones.
Question posed: Whether the proposed transaction could qualify for the special tax regime regulated in Chapter VII of Title VII of the Corporate Income Tax Law. And whether the economic reasons can be considered valid for the purposes of applying the aforementioned special regime.
To apply the special regime for non-monetary contributions, the beneficiary entity must be a resident in Spain and the contributor must maintain a shareholding of at least 5% in its equity before and after the transaction. Furthermore, the entity's main activity may not be the management of movable or immovable property, nor may it be an economic interest group. The stated reasons of structural rationalization, resource optimization, and risk separation are considered economically valid to avoid the application of the prohibition due to tax fraud or evasion.
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