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A natural person enquires whether a value exchange for reorganising their business structure meets legal requirements. The DGT states that the special regime may apply if the entity acquires a majority of voting rights, residency requirements are met, and the operation has valid economic motives rather than a purely fiscal objective.
Question posed: Confirmation that the proposed share exchange operation meets the legally provided requirements to qualify for the "share exchange" tax mechanism provided for in Article 76.5 and 80 of Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
To apply the share exchange regime, the entity must acquire holdings that allow it to obtain the majority of voting rights or increase its majority stake. The residency requirements for the partners and the acquiring entity must be met pursuant to Article 80.1 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.
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