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The DGT confirms that a share acquisition to establish a holding company may qualify for the special share exchange regime if a majority of voting rights is obtained, LIS article 80 requirements are met, and the transaction has valid economic motives rather than purely fiscal objectives.
Question posed: Whether the described transaction 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 entity must acquire holdings that allow it to obtain the majority of voting rights and comply with the requirements of Article 80 of the LIS. Furthermore, pursuant to Article 89.2 of the LIS, the transaction must not have the primary objective of tax fraud or evasion, and must be carried out for valid economic reasons. The stated reasons of reorganization, centralization of management, risk diversification, and succession planning are considered valid.
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