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A company has requested a ruling on whether a share exchange operation, intended to facilitate the entry of executives and the extraction of reserves, can qualify for the special regime. The DGT has ruled that this is possible provided that legal requirements are met and valid economic reasons are demonstrated.
Question posed: Whether the special regime of Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax is applicable to the intended exchange of securities operation, considering the previously mentioned reasons as valid economic motives.
The special regime for the exchange of securities is applicable if the acquiring entity obtains the majority of voting rights and the requirements of Article 80 of the LIS are met. The reasons of facilitating the entry of executives, the extraction of reserves, and the unification of family participation are considered economically valid pursuant to Article 89.2. Regarding dividends from reserves generated prior to the acquisition, the exemption under Article 21 of the LIS shall apply to the portion exceeding the acquisition price of the holding.
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