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The DGT confirms that a physical person's contribution of shares in a rental society to a new company (Newco1) may qualify for the special share exchange regime if legal requirements are met and there is no primary objective of tax fraud or evasion.
Question posed Whether the proposed operation is subject to the special regime regulated in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax, and whether the reasons indicated for proposing the aforementioned operation constitute valid economic reasons for the purposes of applying the cited special regime, as well as the tax treatment that the designed operation may trigger for the purposes of Personal Income Tax, Transfer Tax and Stamp Duty, and Tax on the Increase in Value of Urban Land.
The transaction may be classified as a share exchange if the new entity acquires the majority of voting rights. Under this regime, the partner shall not include income in the Personal Income Tax (IRPF) and the securities shall be valued at their previous tax value. In the Non-Resident Income Tax (ITPAJD), the transaction shall be not subject and exempt if it is considered a restructuring. Neutrality shall not apply if the primary objective is tax fraud or evasion.
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