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The consultant asks whether their restructuring operation qualifies for the special share exchange regime and if valid economic grounds exist. The DGT states that the operation could apply if the beneficiary acquires a majority of voting rights and meets legal requirements, provided it is not for tax fraud or evasion.
Question posed: Whether the proposed restructuring operation 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 and whether valid economic reasons exist.
The transaction may qualify for the share exchange regime if the beneficiary entity acquires shares that allow it to obtain the majority of voting rights and the requirements of Article 80 of the LIS are met. However, the regime shall not apply if the primary objective is fraud, evasion, or the mere obtaining of a tax advantage without valid economic reasons. The verification of economic reasons is a matter of fact that must be assessed by the auditing bodies according to the circumstances of each case.
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