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A consulting entity asks whether a non-cash immovable asset contribution and a share exchange can qualify for the special regime under Corporate Income Tax law. The DGT responds that such arrangements are permissible provided residence requirements, ownership in own funds, economic activity alignment, and valid economic reasons are met.
Cuestión planteada Si la operación de aportación no dineraria, tal y como ha sido descrita anteriormente se calificaría objetivamente dentro del régimen especial previsto en el capítulo VII del título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades.
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