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A credit management company asks whether its operation can benefit from the special share exchange regime. The DGT states that it is possible if the entity acquires a majority of voting rights and legal requirements are met, provided the operation has valid economic motives and is not for tax advantages.
Question posed: Possibility that the projected operation may qualify for the special tax regime regulated 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 the voting rights of the participated entity and comply with the requirements of Article 80 of the LIS. Furthermore, the operation must not have the primary objective of tax fraud or evasion, and must be carried out for valid economic reasons such as the restructuring or rationalization of activities. The improvement of solvency, capitalization, or financial capacity could be considered valid reasons, although their classification depends on the facts.
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