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A family group asks whether the acquisition of a company by a holding can qualify for the special share exchange regime. The DGT states that this is possible if legal requirements are met and valid economic justifications are provided.
Question posed: Whether the described operation may benefit from the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax and whether valid economic reasons exist.
To apply the special regime for the exchange of securities, the entity must acquire holdings that allow it to obtain a majority of voting rights or increase its majority, complying with the residence and valuation requirements of Article 80 of the LIS. Likewise, pursuant to Article 89.2 of the LIS, the operation must not have fraud or tax evasion as its main objective. Reasons related to asset management, simplification of generational succession, and risk diversification could be considered valid economic reasons, although their validation depends on the verification of the facts.
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