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The consultant asks whether a value swap transaction may benefit from the special tax regime. The DGT states that it is possible provided the LIS requirements are met and the transaction is not primarily aimed at tax fraud or evasion.
Question posed: Whether the securities exchange operation proposed in the consultation request 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 a stake that allows it to obtain the majority of voting rights. The residency requirements for the partners and the acquiring entity provided for in Article 80.1 of the LIS must be met. Furthermore, the operation must not have the primary objective of tax fraud or evasion, and must respond to valid economic reasons such as the restructuring or rationalization of activities.
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