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A couple consulted whether their holding company's share acquisition could qualify for the special exchange regime. The DGT states it is possible provided legal requirements are met and the transaction is not primarily aimed at obtaining a fiscal advantage.
Question posed: 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 or increase its majority stake. The requirements of Article 80 of the LIS must be met, and the operation cannot have the primary objective of tax fraud or evasion. Valid economic reasons, such as the restructuring or rationalization of activities, allow for the application of the regime, whereas the mere pursuit of tax advantage prevents it.
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