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Two partners in a group consult whether transferring their shares to a family holding company may qualify for the special share exchange regime. The DGT states that this is possible if the entity acquires a majority of voting rights and legal requirements are met, provided it is not carried out for tax fraud or evasion.
Question posed: Whether the special tax regime regulated in Chapter VII of Title VII of the Corporate Income Tax Law is applicable.
The special regime for the exchange of securities is applicable if the beneficiary entity acquires shares that allow it to obtain the majority of voting rights and the requirements of Article 80 of the Corporate Income Tax Law are met. In this case, the partners shall not include income in their tax base and the securities received shall be valued at the tax value of those transferred. The beneficiary company shall value the shares received at the tax value they had in the assets of the partners. However, the regime shall not apply if the main objective of the operation is fraud, tax evasion, or if it lacks valid economic reasons.
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