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A natural person enquires whether contributions of shares from several entities to a Spanish resident company may qualify for the special regime. The DGT confirms this is possible provided the requirements of ownership and participation are met, and the transaction is not primarily aimed at tax fraud or avoidance.
Question posed: Whether the described transaction could qualify for the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
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 its equity following the transaction. In the case of shares, these must represent at least 5% of the equity of the contributed entity and must have been 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 motives rather than the mere pursuit of a tax advantage.
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