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A natural person asks whether a 22.12% shareholding in a Spanish resident entity qualifies for the special non-cash contribution regime. The DGT states that the regime applies if the minimum participation requirement is met and the transaction has valid economic motives, not merely fiscal ones.
Question posed: Whether the projected contribution meets the requirements provided for the application of the special tax regime regulated in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
In order for the contribution of shares or social interests to qualify for the special regime, the contributor must have held them uninterruptedly during the previous year and maintain a stake of at least 5% in the receiving entity. Furthermore, the contributed entity may not be an economic interest group, a temporary joint venture, nor have the management of movable or immovable property as its main activity. Finally, the transaction must respond to valid economic reasons and not have fraud or tax advantage as its primary objective.
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