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A consultant asks whether a share exchange enabling one entity to acquire control of another meets the special regime conditions for mergers and spin-offs. The DGT responds that such a regime may apply if the conditions in Article 80 of the LIS are met and the objective is not fraud or tax evasion.
Question raised 1.- Whether the projected operation meets the requirements for the application of the special regime for mergers, demergers, contributions of assets, exchange of securities, and change of registered office of a European Company or a European Cooperative Society from one Member State to another of the European Union, as regulated in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
For the exchange of securities to qualify for the tax neutrality regime, the entity acquiring the securities must be a resident in Spain or within the scope of Directive 2009/133/EC, and the shareholders must reside in Spain or the EU. The securities received shall be valued at their tax value and shall retain the acquisition date. The regime shall not apply if the primary objective of the transaction is tax fraud or evasion, or if a spurious tax advantage is sought.
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