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A family group has enquired whether contributing their interests in a community of property to a company, followed by an exchange of shares, may qualify for the special regime under the Corporate Income Tax Act. The Directorate General of Taxes (DGT) has ruled that this is possible provided that the requirements regarding residency, shareholding, and use for economic activity are met, and that the reasons provided are economically valid.
Question posed: Whether the proposed operations may qualify for the special regime of Chapter VII of Title VII of the Corporate Income Tax Act, and whether the reasons provided are considered economically valid for these purposes.
The contribution of an undivided interest in a community of property is considered a special non-monetary contribution pursuant to Article 87.1 of the Corporate Income Tax Act. To qualify for the special regime, the receiving entity must be a resident in Spain, the contributors must maintain at least a 5% shareholding, and the assets must be used for economic activities with commercial accounting. The exchange of securities is applicable if the acquiring entity obtains the majority of voting rights. The proposed reasons of family reorganization and business management are considered economically valid.
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