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A Spanish resident shareholder asks whether contributions of shares from two companies to a third may qualify under the special regime. The DGT states this is possible if participation, duration and absence of purely fiscal motives are satisfied.
Question posed: Whether the described operation could qualify for the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
In order for the contribution of shares or social interests to qualify for the special regime, they must represent at least 5% of the entity's equity and must have been held uninterruptedly during the previous year. Following the contribution, the contributor must maintain a stake of at least 5% in the receiving entity, which must be a resident in Spain or have a permanent establishment. The operation must not have the primary objective of tax fraud or evasion, and must respond to valid economic reasons such as the restructuring or rationalization of activities.
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