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The DGT confirms that the special regime applies to share contributions exceeding 5%, but not to those below 5%.
Question posed: Whether the restructuring operation in question meets the valid economic reasons referred to in Article 89.2 of Law 27/2014, of November 27, on Corporate Income Tax (hereinafter, LIS), and, therefore, whether the special tax neutrality regime regulated in Chapter VII of Title VII of the LIS is applicable.
To apply the special regime for non-monetary contributions, the contributor must hold at least 5% of the equity of the recipient entity. Likewise, the contributed shares must represent at least 5% of the equity of the contributed entity and must have been held uninterruptedly during the previous year. If the main objective of the operation is tax fraud or evasion, or if it is not carried out for valid economic reasons, the tax neutrality regime shall not apply.
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