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The DGT confirms that a share exchange to obtain control of an entity qualifies under the special regime if voting rights are acquired, residency requirements are met, and the primary objective is not fraud or tax evasion.
Question posed: Confirmation that the exchange of securities operation, as described above, would objectively qualify within the special regime provided for in Article 76.5 of 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 entity must acquire a stake that allows it to obtain the majority of voting rights or increase its majority stake. The residency requirements for the partners and the acquiring entity must be met pursuant to Article 80.1 of the LIS. Furthermore, the operation must not have the primary objective of tax fraud or evasion, and must respond to valid economic reasons such as the restructuring or rationalization of activities.
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