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A couple asks whether contributions of shares from various companies to a receiving company may qualify for fiscal neutrality. The DGT states this is possible if voting rights majority is achieved in swaps and a minimum 5% shareholding is met in non-cash contributions, provided the main objective is not fiscal advantage.
Question posed: Whether the described operation could qualify for the regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax, as well as whether the reasons set forth can be considered economically valid.
For the exchange of securities, the entity must acquire the majority of voting rights and comply with the requirements of Article 80 of the LIS. In non-monetary contributions, the holdings must represent at least 5% of the equity of the contributed entity and the contributor must maintain at least a 5% stake in the receiving entity following the transaction. These operations must not have the primary objective of tax advantage, but rather valid economic motives.
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