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The consultant asks whether a share exchange to centralise holdings in a holding company can benefit from the special regime of the Corporate Income Tax. The DGT responds that it is possible provided Articles 76.5 and 80.1 of the LIS are met and the operation is not primarily aimed at fraud or tax evasion.
Question raised: 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.
To apply the special regime for the exchange of securities, the beneficiary entity must acquire shares that allow it to obtain the majority of voting rights and comply with the residency and valuation requirements provided for in the LIS. Furthermore, the transaction must respond to valid economic motives, such as the restructuring or rationalization of activities, and must not have the primary objective of obtaining a tax advantage. The validity of the economic motives presented is a matter of fact that the Administration may verify.
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