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The query examines whether a series of share swaps, the contribution of a building, and dividend distributions can qualify for special tax regimes. The DGT concludes that this is possible provided that requirements regarding participation, residence, and valid economic reasons are met, and that the conditions of the Corporate Income Tax Act (LIS) for dividend exemptions are respected.
Question raised 1) Whether the described operations of exchange of shares and non-monetary contribution may qualify for the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
For the exchange of shares, the special regime is applicable if the majority of voting rights are acquired and the requirements of Article 80 of the LIS are met. Regarding non-monetary contributions, it is required that the contributing entity holds at least 5% of the equity of the recipient entity and that the operation has valid economic reasons. The dividend exemption shall be applicable to the extent that the requirements for participation and taxation in the participated entity provided for in Article 21 of the LIS are met.
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