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A natural person asks whether they can benefit from the special non-monetary contribution regime by transferring shares from two companies to a third. The DGT states that such a regime may apply if participation and residency requirements are met and the transaction has valid economic motives.
Question posed: Whether the application of the special regime of Chapter VIII of Title VII of the consolidated text of the Corporate Income Tax Law is appropriate for the operation proposed.
To apply the special regime for non-monetary contributions, the requirements of Article 94 of the TRLIS must be met, such as the residence of the entities in Spanish territory and a minimum participation of 5% in the equity. Furthermore, the operation must not have fraud or tax evasion as its primary objective, and must respond to valid economic reasons pursuant to Article 96.2 of the TRLIS. The centralization of planning or the generational transfer of business assets may be considered valid economic reasons.
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