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The consultant asks whether a share exchange to restructure their business group can benefit from the special regime of Corporate Income Tax. The DGT states that this is possible if residence and voting majority requirements are met, and the exchange is not primarily aimed at fraud or tax advantage.
Question posed: Whether the exchange of securities transaction proposed in the consultation request may qualify for the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
To apply the special regime for the exchange of securities, the acquiring entity must obtain the majority of voting rights and comply with the residency requirements of both the shareholders and the acquiring entity. Furthermore, the transaction must be driven by valid economic motives, such as the restructuring or rationalization of activities, and must not have the primary objective of obtaining a tax advantage. The validity of the economic motives presented is a matter of fact that the Administration may verify.
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