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The consultant seeks to centralise holdings in entities A and B via a new holding company through a share exchange. The DGT confirms the operation may qualify for the special regime if the holding company obtains a majority of voting rights and legal requirements are met, provided it is not for fraud or tax evasion.
Question posed: Whether the described operation may qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax and whether valid economic reasons exist.
To apply the special regime for the exchange of securities, the beneficiary entity must acquire holdings that allow it to obtain the majority of voting rights in the participated entities. Likewise, the residency and tax valuation requirements provided for in Article 80 of the LIS must be met. Finally, the operation must not have fraud or tax evasion as its main objective, and must be based on valid economic reasons such as the restructuring or rationalization of activities.
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