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A company has requested clarification on whether the contribution of premises, housing, and garages to a new company (Newco) meets the requirements for the special regime for non-monetary contributions. The DGT responds that the transaction may qualify for tax neutrality provided that legal requirements are met and its primary objective is not tax fraud or evasion.
Question raised 1.- Whether the non-monetary contribution transaction of the three premises, the dwelling, and the ten garage spaces, together with their facilities and the subrogated employee, meets the requirements set forth in Article 87 of the Corporate Income Tax Law (LIS) to be classified as a special non-monetary contribution.
The transaction may qualify for the tax neutrality regime if the entity receiving the contribution is a resident in Spain (or has a permanent establishment) and the contributor holds at least 5% of its equity. In this case, capital gains shall not be recognized in the transferor, and the values and seniority shall be maintained in the transferee. However, the regime shall not apply if the primary objective of the restructuring is tax fraud or evasion.
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