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Individuals inquire whether contributions of their shares in a company to two individual holding companies may qualify under the special merger and split regime. The DGT states that this is possible if participation and ownership requirements are met, and if the transaction has valid economic motives and not merely fiscal ones.
Question raised 1. Whether the non-monetary contribution operations proposed are subject to the special regime for mergers, demergers, contributions of assets, exchange of securities, and change of registered office of a European Company or a European Cooperative Society from one Member State to another within the European Union, contained in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
To apply the special regime for non-monetary contributions, the receiving entity must be a resident in Spain and the contributor must maintain a shareholding of at least 5% of the equity. In the case of natural persons, the shares must have been held uninterruptedly during the previous year. Furthermore, the operation must not have the primary objective of tax fraud or evasion, requiring valid economic reasons. Regarding ITP and AJD, restructuring operations are not subject to tax and are exempt under the modalities of onerous transfers and documented legal acts.
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