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An individual has enquired whether the contribution of shares from three operating companies to a Spanish-resident holding company can qualify for the special regime. The DGT indicates that if the requirements regarding shareholding and residence are met, and the transaction is supported by valid economic reasons, the special regime is applicable.
Question posed: Whether the described transaction may qualify for the special tax regime of Chapter VIII, Title VII of the Recast Text of the Corporate Income Tax Law approved by Royal Legislative Decree 4/2004, of March 5.
To apply the special regime for non-monetary contributions, the beneficiary entity must be a resident in Spain or have a permanent establishment. In the case of share contributions by natural persons, these must represent at least 5% of the recipient entity's equity, be from companies resident in Spain that are not involved in the management of movable/immovable property under certain limits, and have been held uninterruptedly during the previous year. Furthermore, the transaction must not have the primary objective of tax fraud or evasion, and must respond to valid economic reasons such as the restructuring or rationalization of activities.
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