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The DGT confirms that a share exchange between family group companies may qualify for the special regime under LIS if the entity acquires a majority of voting rights, residency requirements are met, and the transaction has valid economic grounds rather than purely fiscal motives.
Question raised 1. Whether the application of the special tax regime of Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Tax, is appropriate for the described exchange of securities operation. And, where applicable, the taxation of the income obtained by the contributing partners and their valuation of the securities received in consideration.
If the beneficiary entity acquires the majority of voting rights and the requirements of Article 80 of the LIS are met, the special regime for the exchange of securities may be applied. In this case, the partners shall not include the income in their IRPF taxable base, and the securities received shall be valued at the tax value of those transferred, maintaining their acquisition date. However, the application of the regime requires that the operation does not have the primary objective of tax fraud or evasion, requiring valid economic reasons pursuant to Article 89.2 of the LIS.
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