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A consultant asks whether their shareholding contribution can benefit from the special value exchange regime. The DGT states that this is possible if LIS requirements are met and the operation is not primarily aimed at fraud or tax advantage.
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, specifically whether the share exchange regime is applicable in the case of the majority shareholder.
To apply the share exchange regime, the entity must acquire holdings that allow it to obtain the majority of voting rights and comply with the requirements regarding residence and tax valuation. The regime shall not apply if the primary objective of the transaction is tax fraud or evasion, or if it is not carried out for valid economic reasons. Estate planning and generational succession motives could be considered economically valid, although their classification depends on the facts.
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