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A query was raised regarding whether a restructuring involving a securities exchange and contributions of shares can qualify for the special regime under the Corporate Income Tax Act (LIS) and if valid economic reasons exist. The DGT indicates that this is possible provided that requirements concerning voting rights majorities, minimum equity participation, and the absence of purely tax-driven motives are satisfied.
Cuestión planteada Si las operaciones descritas pueden acogerse al régimen fiscal previsto en el Capítulo VII del Título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades y si existen motivos económicos válidos.
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