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A company inquired whether a group reorganisation could benefit from the special non-cash contributions regime. The DGT states that this is possible if a minimum 5% ownership stake in shareholders' equity is maintained and the transaction is driven by valid economic reasons, not merely tax advantages.
Question posed: Whether the described transaction can qualify for the special tax regime under Chapter VII of Title VII of Corporate Income Tax Law 27/2014, of November 27.
To apply the special regime for non-monetary contributions, the entity receiving the contribution must be a resident in Spain or have a permanent establishment, and the contributor must hold at least 5% of its equity, either before or after the transaction. Furthermore, the transaction must not have the primary objective of tax fraud or evasion, and must respond to valid economic motives such as the restructuring or rationalization of activities. The mentioned motives of structural reorganization and risk management may be considered valid.
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