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A company has requested clarification on whether the contribution of shares in other entities by its shareholders can qualify for the special regime for asset contributions under Corporate Income Tax. The DGT indicates that this is possible provided that requirements regarding residence, shareholding percentage, and uninterrupted ownership are met, and that valid economic reasons exist.
Question posed: Confirmation that the non-monetary contribution transaction of securities from entity B, as previously described, would objectively qualify within the special regime provided for in Chapter VIII, Title VII of the consolidated text of the Corporate Income Tax Law.
To apply the special regime for non-monetary contributions, the receiving entity must be a resident in Spain and the contributor must maintain a stake of at least 5% in the entity's equity following the transaction. In the case of shares, these must represent at least 5% of the equity of the contributed entity and must have been held uninterruptedly during the previous year. Furthermore, the transaction must respond to valid economic reasons and must not have the primary objective of tax fraud or evasion.
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