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A query was raised regarding whether the contribution of participation shares in a community of property consisting of rural estates can fall under the special regime for non-monetary contributions. The Directorate General for Taxes (DGT) ruled that if the ideal share constitutes a special non-monetary contribution and the requirements regarding allocation to an economic activity and minimum participation are met, it is permissible.
Question posed: Whether the described transaction may qualify for the special tax regime under Chapter VIII, Title VII of the Recast Text of the Corporate Income Tax Law approved by Royal Legislative Decree 4/2004, of March 5.
The contribution of a co-owner's ideal share is considered a special non-monetary contribution pursuant to Article 94.1 of the TRLIS. To qualify for the special regime, each contributor must maintain a stake of at least 5% in the acquiring entity and the assets must be used for economic activities. If the activity is carried out by a civil society that maintains accounting records in accordance with the Commercial Code, the requirements for use in economic activities are met. Furthermore, the transaction must have valid economic reasons so as not to fall under the assumption of tax fraud or evasion under Article 96.2 of the TRLIS.
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