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An shareholder wishes to transfer their shares in two companies to a new holding company to obtain a majority of voting rights. The DGT states that the transaction may qualify for the share exchange regime provided legal requirements are met and the primary objective is not fraud or tax evasion.
Question raised: Whether the proposed transaction can benefit from the special regime of Chapter VII of Title VII of the Corporate Income Tax Law, and whether the reasons set forth are considered economically valid for these purposes.
The transaction may be eligible for the securities exchange regime if the holding company acquires shares that allow it to obtain the majority of voting rights in the contributed entities. To this end, the requirements of Article 80 of the LIS must be met, allowing the income not to be included in the tax base and maintaining the tax values and acquisition dates. However, the regime shall not be applicable if the primary objective of the restructuring is tax fraud or evasion, or if it lacks valid economic reasons.
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