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The consultant proposes exchanging their holdings in entity A for shares in group C via entity B. The DGT states that the transaction may qualify under the special regime if entity B acquires a majority of voting rights and residence and anti-fraud requirements are met.
Question raised: 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.
To apply the special regime for the exchange of securities, the acquiring entity must obtain the majority of the voting rights in the participated entity or increase its participation if it already holds the majority. The residence requirements for the partners and the acquiring entity provided for in Article 80.1 of the LIS must be met. Furthermore, the operation must not have the main objective of tax fraud or evasion, and must respond to valid economic reasons rather than a mere purpose of tax advantage.
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