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A company asks whether acquiring shares in other companies to centralise management can qualify for the special share exchange regime. The DGT responds that this is possible if the conditions of Article 80 of the LIS are met and the transaction has valid economic motives, not merely fiscal ones.
Question raised 1) Whether the described operation may 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. The operation must not have the primary objective of tax fraud or evasion, but rather valid economic motives such as the restructuring or rationalization of activities. The stated motives of management centralization, cost savings, and financial efficiency are considered valid for this purpose.
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