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A query was raised regarding whether a non-monetary contribution of shares can qualify for the special corporate restructuring regime. The DGT indicates that this regime is applicable provided that the requirements for participation and ownership are met, and the transaction is driven by valid economic reasons rather than purely tax-driven motives.
Question posed: Whether the described transaction may qualify for the special tax regime of Chapter VIII, Title VII of the Recast Text of the Corporate Income Tax Law approved by Royal Legislative Decree 4/2004, of March 5.
To apply the special regime for non-monetary contributions, the requirements of Article 94 of the TRLIS must be met, such as the residence of the receiving entity, a minimum participation of 5% in the equity, and the uninterrupted possession of the shares during the previous year. Furthermore, pursuant to Article 96.2 of the TRLIS, 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.
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