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A query was raised regarding whether a non-monetary contribution of shares could qualify for the special regime for asset contributions. The DGT indicates that if the requirements for participation and residence are met, and provided the transaction is supported by valid economic reasons, the special regime shall apply.
Question raised: 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 and a minimum participation of 5% in the equity. Furthermore, pursuant to Article 96.2 of the TRLIS, the transaction must not have fraud or tax evasion as its primary objective, and must respond to valid economic reasons rather than a mere purpose of obtaining a tax advantage. Reasons of organizational optimization, centralization of management, or succession simplification may be considered valid.
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