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The inquiry asks whether a share swap between three physically-owned companies qualifies for the special regime. The DGT states that the regime may apply if the beneficiary acquires a majority of voting rights and residence requirements are met, along with the absence of tax fraud.
Question posed: Whether the share exchange transaction as described above would be qualified
For a transaction to constitute a share exchange, the acquiring entity must obtain the majority of voting rights or increase its shareholding through the allocation of new securities to the shareholders. The special regime requires that the shareholders reside in Spain or the EU and that the acquiring entity be a resident of Spain or fall within the scope of Directive 2009/133/EC. The regime shall not apply if the primary objective is tax advantage without valid economic reasons, such as the restructuring or rationalization of activities.
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