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A taxpayer inquired whether the contribution of shares from one entity to another could qualify for the special restructuring regime. The DGT ruled that this is possible provided that participation and residency requirements are met, and that the transaction is driven by valid economic motives rather than solely for tax advantages.
Question posed: Whether the proposed transaction involving the contribution by the inquirer of the shares of entity A to entity H may qualify for the special regime under Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax. In particular, whether the reasons for which the contribution is intended to be made can be considered valid economic reasons within the terms required by Article 89 of the LIS.
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