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An insurance portfolio company asks whether the special fiscal neutrality regime can be applied in a share exchange solely directed at current shareholders of entity B. The DGT confirms it is possible provided the LIS requirements are met and the operation's main objective is not fiscal advantage.
Question posed - Whether the special regime of tax neutrality may be applicable to the proposed exchange of securities transaction. Specifically, it is desired to know if there is any particularity due to the fact that the possibility of participating in the exchange is offered exclusively to those shareholders of entity B who are already shareholders of the applicant.
To apply the special regime for the exchange of securities, the acquiring entity must obtain a greater shareholding in entity B, already holding the majority of voting rights, and comply with the requirements of Article 80 of the LIS. The regime shall not apply if the primary objective of the transaction is fraud, evasion, or the mere obtaining of a tax advantage without valid economic reasons. The assessment of economic reasons is a question of fact to be determined by the auditing bodies according to the circumstances of the case.
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