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A holding company plans to amend its statutes to replace its current shares with two new classes having different economic and political rights. The DGT states that this operation is considered a share swap, requiring the inclusion of the difference between market and fiscal value in the taxable base.
Question posed: Would the social agreement that the consultant intends to propose to the General Meeting for the modification of the social shares imply, for the companies holding 100% of the share capital of entity X, the execution of an exchange that would require the inclusion of some type of income in the taxable base of the Corporate Income Tax?
The substitution of securities issued by an entity for others with different economic rights constitutes a share exchange pursuant to Article 17.4 of the LIS. Therefore, entities performing the exchange must include in their tax base the difference between the market value of the acquired shares and the tax value of the shares transferred. Likewise, the new shares must be valued at their normal market value.
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