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A company has requested clarification on whether a share swap operation intended to create a holding structure can qualify for the special tax regime. The Directorate General of Taxes (DGT) has ruled that this is possible, provided that all legal requirements are met and the primary purpose of the transaction is not tax fraud or evasion.
Question posed: Whether the described operation of exchange of securities 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.
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 and comply with the requirements of Article 80 of the LIS. Furthermore, the operation must not have the primary objective of tax fraud or evasion, and must respond to valid economic motives such as the restructuring or rationalization of activities. The economic motives alleged by the taxpayer to organize its holding structure are considered valid.
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