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A taxpayer inquired whether contributing the usufruct of shares and a small portion of the bare ownership to an entity could qualify for the special regime for non-monetary contributions. The Directorate General for Taxes (DGT) ruled that it is impossible to meet the legal requirements for either part of the contribution.
Question raised 1) Whether the described operation 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.
The contribution of the usufruct of shares cannot qualify for the special regime because said right is not related to an economic activity. On the other hand, the contribution of the bare ownership of the shares does not meet the requirement that the holding represents at least 5% of the recipient entity's equity.
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