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A natural person inquires whether the contribution of shares from two entities to a new holding company may qualify for the special restructuring regime. The DGT indicates that it is applicable if the requirements regarding participation, uninterrupted ownership, and the activity of the entities are met, and if valid economic reasons exist.
Question posed: Whether the special tax regime of Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax, is applicable to the indicated non-monetary contribution.
The special regime of the CIT Act is applicable to non-monetary contributions if the receiving entity is resident in Spain, the contributor retains at least 5% of the equity following the transaction, and the shares have been held uninterruptedly during the previous year. Furthermore, the contributed entities must not be economic interest groups nor have the management of movable or immovable property as their main activity. Finally, the transaction must respond to valid economic reasons and must not have the primary objective of tax fraud or evasion.
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