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The consultant asks whether contributions of subsidiary shares to a new entity may qualify for the special merger and asset contribution regime. The DGT states this is possible if participation and ownership requirements are met and the transaction has valid economic motives.
Question posed: Whether the described transaction, in accordance with the elements presented and the spirit of the transaction, may qualify for the special regime for mergers, demergers, contributions of assets, and exchange of securities.
In order for a non-monetary contribution of shares or interests to qualify for the special regime under Article 87 of the LIS, the receiving entity must be a resident in Spain and the contributor must maintain a stake of at least 5% in the entity's equity following the transaction. Furthermore, the transaction must not have the primary objective of tax fraud or evasion, and must correspond to valid economic reasons rather than the mere pursuit of a tax advantage. The validity of the economic reasons is a matter of fact that the Administration may verify.
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