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Some partners inquire whether transferring their shares in entity A to a new entity B may qualify for the special share exchange regime. The DGT responds that this is possible if entity B acquires a majority of voting rights and residence and economic justification requirements are met.
Question posed: Possibility of applying the special regime for mergers, demergers, contributions of assets, exchange of securities, and change of registered office of a European Company, as set forth in Chapter VII of Title VII of the Corporate Income Tax Act, to the non-monetary contribution of the social shares of entity A to a newly incorporated entity, entity B.
The operation may be subject to the regime under Chapter VII of Title VII of the LIS if entity B acquires holdings that allow it to obtain the majority of voting rights in entity A and the requirements of article 80 of the LIS are met. In this case, the partners shall not include in their tax base the income derived from the exchange, and the securities shall receive the tax value of those transferred. Notwithstanding, the regime shall not be applicable if the principal objective of the operation is fraud, tax evasion, or if it lacks valid economic reasons pursuant to article 89.2 of the LIS.
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