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A natural person enquires whether the special tax regime for value exchange can be applied in a control acquisition transaction. The DGT states that it may be applied provided the LIS requirements are met and the transaction does not have fraud or tax evasion as its primary objective.
Question posed: Whether the application of the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax is appropriate.
To apply the special regime for the exchange of securities, the entity must acquire holdings that allow it to obtain the majority of voting rights and comply with the residency requirements for partners and the entity pursuant to Article 80.1 of the LIS. Likewise, the operation must not have the primary objective of tax fraud or evasion, and must respond to valid economic reasons pursuant to Article 89.2 of the LIS. The assessment of whether the proposed objectives constitute valid economic reasons is a question of fact that the Administration may verify.
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