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Three individuals have enquired whether contributing their shares in a company to three other companies can qualify for the special regime for non-monetary contributions. The Directorate General for Taxes (DGT) has ruled that this is possible provided that requirements regarding residency, shareholding percentages, and valid economic reasons are satisfied.
Question posed: Whether the application of the special regime under Chapter VIII of Title VII of the recast text of the Corporate Income Tax Law is appropriate for the transaction presented, and whether the alleged reasons are considered economically valid for these purposes.
To apply the special regime for non-monetary contributions, the beneficiary entity must be a resident in Spain and the contributor must hold at least 5% of its equity. In the case of shares or holdings, the contributed entity must be a resident in Spain, must not be an economic interest group or a temporary joint venture, and must not have the management of movable or immovable property as its main activity. Furthermore, the transaction must respond to valid economic reasons, such as the restructuring or rationalization of activities, and must not have the primary objective of tax fraud or evasion.
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