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A natural person proposes an enterprise reorganisation by contributing various shareholdings to a new company (NEWCO). The DGT examines whether these transactions may qualify for the special non-cash contribution regime under the Corporate Income Tax and the Inheritance Tax.
Question raised 1) If the natural person PF2 were to pass away prior to the moment they undertake the proposed business reorganization, would the consolidation in their estate of full ownership of 15.364% of the shares of A be eligible for the family business reduction.
The contribution of all shares of X5 to the NEWCO may qualify for the share exchange regime if a majority of voting rights are obtained and the requirements of Article 80 of the LIS are met. The contributions of the shares of X1, X3, and X6 may qualify for the non-monetary contribution regime under Article 87 of the LIS if a holding of at least 5% in the receiving entity is maintained and the requirements of ownership and activity are met. However, the contribution of the usufruct could not qualify for this regime as it is not linked to an economic activity.
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