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A taxpayer has enquired whether the contribution of shares from several entities to a receiving company can qualify for the special regime under the Corporate Income Tax Act (LIS). The DGT analyses the requirements regarding shareholding, uninterrupted ownership, and the nature of both the contributing and receiving entities.
Question raised 1) Whether the described transaction can qualify for the special tax regime under Chapter VII of Title VII of Corporate Income Tax Law 27/2014, of November 27.
To apply the special regime for non-monetary contributions, the recipient entity must be a resident in Spain or have a permanent establishment, and the contributor must maintain a stake of at least 5% in the recipient's equity. The contributed shares must represent at least 5% of the contributor entity's equity and must have been held uninterruptedly during the previous year. The regime shall not apply if the contributing entity's primary activity is the management of movable or immovable property or if the transaction lacks valid economic reasons.
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