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A consulting entity proposes a total demerger, an exchange of shares, and a non-monetary contribution of shares. The DGT analyses whether these operations qualify for the special tax regime for business reorganisations.
Question posed: Whether the described operations may qualify for the special tax regime under Chapter VIII, Title VII of the Recast Text of the Corporate Income Tax Law approved by Royal Legislative Decree 4/2004, of March 5.
Total demerger is valid if carried out within a commercial framework and shareholders receive shares on a proportional basis. The exchange of securities requires the acquiring entity to obtain the majority of voting rights and comply with residency requirements. The non-monetary contribution of shares requires that they represent at least 5% of equity and are held uninterruptedly during the previous year. All such operations must be carried out for valid economic reasons and not for the purpose of obtaining a tax advantage.
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