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The consultant asks whether a share exchange to establish a holding meets the special regime conditions under LIS and has valid economic grounds. The DGT responds that the regime may apply if the entity acquires a majority of voting rights and the conditions in Article 80 are met, provided it is not for tax fraud or evasion.
Question posed: Whether the projected transaction meets the requirements for the application of the special regime under Chapter VII of Title VII of the Corporate Income Tax Law, and in particular, whether it can be understood to be carried out for valid economic reasons.
The tax neutrality regime shall be applicable if the beneficiary entity acquires holdings 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 such case, the partners shall not include income in their tax base and the securities shall receive the tax value of those transferred, maintaining their acquisition date. Notwithstanding, the regime shall not apply if the primary objective of the transaction is fraud, tax evasion, or the mere obtaining of a tax advantage without valid economic reasons.
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