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A consultancy firm proposes transferring its shares to another entity to enable it to hold 100% of the capital. The DGT states that the transaction may qualify for the special exchange regime provided legal requirements are met and the operation is not primarily aimed at fraud or tax advantage.
Question raised: Whether the described transaction 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 voting rights and comply with the residence requirements and Directive 2009/133/EC. Furthermore, the transaction must not have the primary objective of tax fraud or evasion, and must be carried out for valid economic reasons such as the restructuring or rationalization of activities. The economic reasons alleged by the taxpayer could be considered valid, although their classification depends on the factual circumstances.
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