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The consultant asks whether contributions of shares from several entities to a new holding company can benefit from the special non-cash contribution regime. The DGT responds that it applies if participation and residency requirements are met and if the transaction has valid economic motives beyond tax advantages.
Question posed: Whether the non-monetary contribution described is eligible for the special tax regime under Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
The special regime is applicable if the receiving entity is resident in Spain, the contributor retains at least 5% of the equity following the transaction, and the shares have been held uninterruptedly during the previous year. Furthermore, the transaction must not have the primary objective of tax fraud or evasion, and must respond to valid economic reasons such as the rationalization of activities or the management of business interests. Reasons such as centralization of management, simplification of succession, and improvement of the holding structure may be considered valid.
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