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A physical person enquires whether contributing their shares in two companies to a newly established entity may qualify for fiscal neutrality. The DGT responds that this is possible if minimum shareholding, residency and entity activities requirements are met, provided it is not done for tax fraud or advantage.
Question raised 1. Confirmation that the aforementioned non-monetary contribution transaction falls within the definition provided in Article 87.1 of Law 27/2014, of November 27, on Corporate Income Tax.
The contribution of shares by a natural person may qualify for the tax neutrality regime if the receiving entity is a resident in Spain and the contributor maintains at least 5% of its equity. The contributed shares must represent at least 5% of the equity of the contributed entities and must have been held uninterruptedly during the previous year. This regime shall not apply if the principal objective of the transaction is fraud, evasion, or the mere obtaining of a tax advantage without valid economic reasons.
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