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The consultant asks whether contributions of shares from two natural persons to their company can qualify for the special regime of mergers, splits and asset contributions. The DGT states this is possible if participation and ownership requirements are met, provided the transaction has valid economic motives and is not solely for tax advantages.
Question posed: Whether the described operation could qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
For non-monetary contributions of shares to qualify for the special regime, the receiving entity must be a resident in Spain or have a permanent establishment. The contributor must have held the shares uninterruptedly during the previous year and maintain a stake of at least 5% in the entity's equity following the contribution. Furthermore, the transaction must not have the primary objective of tax fraud or evasion, and must respond to valid economic reasons rather than a mere purpose of obtaining a tax advantage.
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