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A query is made as to whether an operation involving the acquisition of shares in two family companies may qualify for the special share exchange regime. The DGT indicates that the operation fits the definition of a share exchange and that generational succession constitutes a valid economic reason for applying said regime.
Question raised: Whether the aforementioned operation may qualify for the special tax regime under Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
The proposed operation is covered by Article 76.5 of the LIS as it allows for the acquisition of the majority of voting rights. To apply the special regime, the residency and acquiring entity requirements of Article 80.1 of the LIS must be met. The purpose of facilitating generational succession is considered a valid economic reason, preventing the operation from being classified as being carried out for the purpose of obtaining a tax advantage under Article 89.2 of the LIS.
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