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A taxpayer asks whether contributions of shares in two entities to a new company (NEWCO) may qualify for the special restructuring regime. The DGT states that this is possible if the minimum shareholding, uninterrupted ownership, and absence of purely fiscal motives are met.
Question posed: Confirmation that, according to the above, the non-monetary contribution operations described could qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
The contribution of shares or equity interests by natural persons may qualify for the special regime if the receiving entity is resident in Spain, the contributor retains at least 5% of the equity of the new entity, and the contributed interests represent at least 5% of the equity of the original entities. Furthermore, the interests must have been held uninterruptedly during the previous year and the operation must not have the primary objective of fraud or tax advantage without valid economic reasons. If these conditions are met, the values and acquisition dates of the interests are maintained to avoid the recognition of income.
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