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A shareholder inquired whether the special regime for contributing shares from holdings in two companies to a third company could be applied. The Directorate General for Taxes (DGT) ruled that it is applicable provided that requirements regarding residency, percentage of participation, and uninterrupted ownership are met, and provided there are valid economic reasons.
Question raised: Whether the application of the special regime under Chapter VIII of Title VII of the consolidated text of the Corporate Income Tax Law is appropriate for the proposed transaction. And whether the alleged reasons are considered economically valid for these purposes.
The special regime is applicable if the beneficiary entity is resident in Spain, the contributor maintains at least 5% of the entity's equity following the contribution and holds the shares uninterruptedly during the previous year. It shall not apply if the main objective of the transaction is tax fraud or evasion, or if it lacks valid economic reasons. Reasons of restructuring, improvement of solvency, or organizational rationalization may be considered economically valid.
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