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The query asks whether social shares transferred from entity B to entity A, resident in Spain, can qualify for the special restructuring regime. The DGT states that this is possible if participation and uninterrupted ownership conditions are met, and if the transaction has valid economic motives.
Question posed: Whether the special regime for mergers, demergers, contributions of assets, exchange of securities, and change of registered office of a European company or a European cooperative society from one Member State to another of the European Union, contained in Chapter VII of Title VII of the Corporate Income Tax Law, is applicable to the proposed business restructuring operation.
In order for the contribution of shares or social interests to qualify for the special regime, the receiving entity must be a resident in Spain or have a permanent establishment. The contributor must have held the interests uninterruptedly during the previous year and maintain a stake of at least 5% in the equity of the receiving entity following the transaction. Furthermore, the transaction must not have the primary objective of tax fraud or evasion, and must respond to valid economic reasons rather than the mere pursuit of a tax advantage.
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