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A natural person enquires whether contributions of shares from three companies to a new entity (Newco) may qualify for the special restructuring regime. The DGT determines that if the requirements of ownership and participation are met, the transaction constitutes a non-cash contribution subject to the fiscal neutrality regime.
Question raised: Whether the special regime of Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax is applicable to the transaction described above
The transaction is classified as a non-monetary contribution pursuant to Article 87.1 of the LIS. To apply the special regime, the receiving entity must be a resident in Spain and the contributor must maintain a shareholding of at least 5% of the entity's equity. Furthermore, 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 these requirements are met, the values and the seniority of the shares are maintained, without integrating income into personal taxation.
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