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A query was raised regarding whether a series of non-monetary contributions, total demergers, and share exchanges can qualify for the special tax regime under the Corporate Income Tax Act (LIS). The Directorate General for Taxes (DGT) ruled that this is possible provided the objective requirements for each operation are met and their primary purpose is not tax evasion or obtaining an undue tax advantage.
Question posed: Whether the described operations may qualify for the special tax regime of Chapter VII of Title VII of the Corporate Income Tax Law 27/2014, of November 27.
For the non-monetary contribution, it is required that the receiving entity be a resident in Spain and that the contributor holds at least 5% of its equity before and after the operation, having held the shares uninterruptedly during the previous year. In the case of a total demerger, it may qualify for the regime if carried out in accordance with commercial regulations and the allocation of shares is proportional. The exchange of shares requires that the acquiring entity obtains the majority of voting rights and complies with the requirements of Article 80 of the LIS. In all cases, the operation must respond to valid economic reasons and not to a mere purpose of obtaining a tax advantage.
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