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A query was raised regarding whether an acquisition of shares to obtain control of several companies may qualify for the special share exchange regime and if valid economic reasons exist. The DGT concludes this is possible provided the requirements of Articles 76.5 and 80.1 of the LIS are met and the primary purpose of the transaction is not tax advantage.
Question raised: Whether the described operation may qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax and whether valid economic reasons exist.
To apply the special regime for the exchange of securities, the entity must acquire holdings that allow it to obtain the majority of voting rights and comply with the residence and valuation requirements of Article 80.1 of the LIS. Furthermore, the operation must not have the primary objective of tax fraud or evasion, and must respond to valid economic reasons such as the restructuring or rationalization of activities. Reasons such as centralization of management, optimization of resources, joint financial management, and unification of tax consolidation are considered valid according to Article 89.2 of the LIS.
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