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A shareholder asks whether contributing shares in two entities to a new company (NEWCO) can be taxed under the value exchange regime. The DGT states that the tax-neutral regime applies if voting majority and other LIS requirements are met, provided it is not for fraud or evasion.
Question posed: Whether, in accordance with the foregoing, the described operation could 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.
La operación puede ser un canje de valores si la entidad que adquiere las participaciones obtiene la mayoría de los derechos de voto. Si se cumplen los requisitos del artículo 80 de la LIS, el socio no integrará renta en su base imponible del IRPF y los valores se valorarán por su valor fiscal anterior. No obstante, el régimen no se aplicará si el objetivo principal es la ventaja fiscal sin motivos económicos válidos.
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