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The DGT confirms that share exchanges to form a new holding may qualify for tax neutrality if legal requirements are met and the main objective is not fiscal advantage.
Question raised 1. Whether the securities exchange operation proposed in the consultation request may benefit from the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax and whether valid economic reasons exist.
To apply the tax neutrality regime in a securities exchange, the beneficiary entity must acquire the majority of voting rights and the requirements of Article 80 of the LIS must be met. The transaction must not have the primary objective of tax fraud or evasion, but rather valid economic motives. If this regime is applied, the partners shall not include income in their IRPF, and the securities shall maintain their value and tax acquisition date. Likewise, dividends received by the new entity could be exempt pursuant to Article 21 of the LIS if the minimum participation and the required period are maintained.
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