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A natural person proposes to transfer shares from two companies to a third to obtain a majority of voting rights. The DGT states that the operation may fall within the share exchange regime provided legal requirements are met and the primary objective is not fraud or tax evasion.
Question posed: Whether the proposed restructuring transaction can qualify for the regime provided for in Chapter VII of Title VII of the LIS, as well as whether the economic reasons can be considered valid for the purposes of its application.
The transaction may be eligible for the share exchange regime if the acquiring entity obtains the majority of voting rights and the requirements of Article 80 of the LIS are met. In this case, the partner shall not include income in their personal income tax base, and the securities shall be valued at their previous tax value. However, the regime shall not be applicable if the primary objective is tax fraud or evasion, or if there are no valid economic reasons. The verification of these reasons is a matter of fact that must be determined by the Administration according to the circumstances of each case.
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