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A consulting company raises the issue of selling shares that were previously swapped. The DGT states that if the subsequent sale aims to secure a tax advantage for shareholders, the original share swap would fail to meet the requirement of valid economic motives and would be excluded from the special regime.
Question posed: Whether the shares acquired by X maintain the same date and the same value they had as natural persons prior to their contribution to X.
Si la transmisión de las participaciones por parte de la sociedad se realiza tras un canje de valores, podría influir en la determinación del propósito principal de dicha operación. Si la venta posterior no beneficia el desarrollo de la actividad de la sociedad sino a sus socios mediante una ventaja fiscal, el canje no se consideraría realizado por motivos económicos válidos. En tal caso, la operación quedaría excluida del régimen fiscal especial de neutralidad previsto en el TRLIS.
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