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The consultant asks whether a reorganisation through the acquisition of shares can benefit from the tax neutrality regime. The DGT responds that it is possible if majority voting rights and residency requirements are met, and if the transaction has valid economic grounds.
Question posed: Whether the proposed restructuring operation may qualify for the tax neutrality regime provided for in Chapter VII of Title VII of Law 27/2014 on Corporate Income Tax.
To apply the special regime for the exchange of securities, the acquiring entity must obtain the majority of voting rights and comply with the requirements of Article 80 of the LIS. The transaction must not have the primary objective of tax fraud or evasion, and must be carried out for valid economic reasons such as the restructuring or rationalization of activities. Reasons concerning succession planning, risk separation, centralization of decisions, and investment efficiency are considered economically valid pursuant to Article 89.2 of the LIS.
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