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A taxpayer inquires whether the contribution of shares from entity B to entity A, a resident in Spain, may qualify for the special regime under the Corporate Income Tax Act (LIS). The DGT indicates that this is possible provided that the shareholding percentages are met and the primary purpose is not to obtain a tax advantage.
Question raised
To apply the special regime for non-monetary contributions, the recipient entity must be a resident in Spain or have a permanent establishment. The contributor must have held the shares uninterruptedly during the previous year and must maintain a shareholding of at least 5% of the recipient entity's equity following the transaction. Furthermore, the transaction must not have the primary objective of tax fraud or evasion, and must respond to valid economic motives rather than the mere pursuit of a tax advantage.
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