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A query was raised regarding whether the creation of a holding company through the acquisition of shares could qualify for the special share exchange regime. The Directorate-General for Taxes (DGT) ruled that this is possible, provided that all legal requirements are satisfied and the primary purpose of the transaction is not tax fraud or evasion.
Question raised 1) Whether the described transaction may qualify for the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
The transaction may qualify for the special regime for the exchange of securities if the beneficiary entity acquires shares that allow it to obtain the majority of voting rights and the requirements of Article 80 of the LIS are met. The reasons of management centralization, resource optimization, and improvement of solvency are considered valid economic reasons pursuant to Article 89.2 of the LIS. Likewise, the dividend exemption shall be applicable if the requirements of Article 21 of the LIS are met.
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