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A Spanish company asks whether the transfer of shares from a subsidiary to a non-resident entity to gain control through a share swap may qualify for the tax neutrality regime. The DGT responds that such an operation may apply to the regime provided it does not have the primary objective of tax fraud or evasion.
Question raised
The securities exchange operation may qualify for the tax neutrality regime under Chapter VII of Title VII of the LIS if the requirements of Article 80 are met. In this case, the contributing company shall not include in its tax base the income derived from the exchange, and the securities received shall be valued at their tax value. However, the regime shall not apply if the primary objective of the operation is tax fraud or evasion, or if it seeks a spurious tax advantage without valid economic reasons.
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