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A taxpayer enquires about the tax treatment of contributing shares from several companies to a new entity. The DGT examines whether the share exchange regime applies to entities B and C, and the non-cash contributions regime to the others.
Question raised in Corporate Income Tax:
For entities B and C, the share exchange regime may be applied if the new company obtains the majority of voting rights and the requirements of Article 80 of the LIS are met. The contribution from entity A is not neutral because the holding is less than 5% of its equity. The contribution from entity D cannot benefit from the regime of Article 87 of the LIS because its main activity is the management of real estate assets. The reasons for grouping management and succession planning are considered valid economic reasons.
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