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A natural person asks whether they can apply the special regime for mergers and non-cash contributions by transferring shares from their companies to a new holding. The DGT states that this is possible if the shareholding and ownership requirements are met, provided the transaction has valid economic motives.
Question raised: Possibility of applying, to the described corporate restructuring operations, the special regime for mergers, demergers, contributions of assets, exchange of securities, and change of registered office of a European company or a European cooperative society from one Member State to another within the European Union, regulated in Chapter VII of Title VII of the Corporate 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 shareholding of at least 5% in the entity's equity following the transaction. In the case of contributions of shares by natural persons, these must represent at least 5% of the equity of an entity that is not an economic interest group nor has the management of movable or immovable property as its main activity, and must be held uninterruptedly during the previous year. Furthermore, the transaction must not have the primary objective of tax fraud or evasion, and must respond to valid economic reasons rather than the mere pursuit of a tax advantage.
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