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A couple asks whether transferring their stakes in six companies to a new holding company qualifies for the special exchange regime. The DGT confirms it is possible if the holding acquires a majority of voting rights, the conditions of Article 80 of the LIS are met, and the transaction has genuine economic justification rather than a purely fiscal objective.
Question posed: Whether the described operation could 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.
To apply the special regime for the exchange of securities, the beneficiary entity must acquire shares that allow it to obtain the majority of voting rights and comply with the requirements of Article 80 of the LIS. Likewise, the operation must not have fraud or tax evasion as its main objective, and must be carried out for valid economic reasons pursuant to Article 89.2 of the LIS. Reasons of operational centralization, organizational rationalization, management improvement, and image consolidation may be considered valid.
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