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The consultant asks whether a share swap followed by a merger of a fully owned entity may benefit from the special tax regime. The DGT confirms this is possible provided the LIS requirements are met and the operation is not primarily aimed at obtaining tax advantages.
Question posed: Whether the described operations may qualify for the special tax regime under Chapter VII of Title VII of the Corporate Tax Law 27/2014, of November 27.
For the exchange of securities, the entity must acquire the majority of voting rights and comply with the requirements of Article 80.1 of the LIS. In the case of a merger by absorption, it may qualify for the special regime if it meets the requirements of commercial law and its primary objective is not tax fraud or evasion. Reasons such as restructuring, simplification of business models, and resource management may be considered valid economic reasons pursuant to Article 89.2 of the LIS.
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