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Three siblings inquired whether a restructuring involving a share exchange and non-monetary contributions could qualify for the special regime under the Corporate Income Tax Act (LIS) based on valid economic reasons. The Directorate General of Taxes (DGT) ruled that this is possible provided that the legal requirements regarding shareholding, residence, and economic activity are satisfied.
Question raised 1) Whether the proposed transaction may qualify for the special regime of Chapter VII of Title VII of the Corporate Income Tax Law, and whether the reasons set forth are considered economically valid for these purposes.
The special regime for the exchange of securities is applicable if the acquiring entity obtains the majority of voting rights and the requirements of Art. 80.1 LIS are met. For non-monetary contributions, it is required that the contributor holds at least 5% of the equity, that the entities do not have the management of movable assets as their main activity, and that the shares are held uninterruptedly during the previous year. The reasons of management autonomy and business development are considered economically valid pursuant to Art. 89.2 LIS.
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