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A taxpayer has enquired whether the contribution of shares from three entities to a receiving company can qualify for the special regime for mergers and asset contributions. The DGT indicates that this is possible provided that legal requirements are met and the transaction is supported by valid economic reasons.
Question posed: Whether the described transaction may qualify for the special tax regime under Chapter VII of Title VII of Law 27/2014, of November 27.
The contribution of shares may qualify for the special regime under Chapter VII of Title VII of the LIS if the requirements of Article 87 are met, such as the residence of the receiving entity, the minimum participation of 5% in equity, and uninterrupted ownership during the previous year. Furthermore, the transaction must not have the primary objective of tax fraud or evasion, and must correspond to valid economic reasons pursuant to Article 89.2 of the LIS. The intention to rationalize activities and improve the operating structure may be considered a valid economic reason.
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