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Shareholders have enquired whether contributing their shares in a company to a new holding company can be considered a securities exchange. The DGT indicates that this is possible provided that legal requirements are met and the primary purpose of the transaction is not fraud or tax advantage.
Question raised: Whether the contribution of all shares of company A held by the three partners to the newly incorporated company B is considered a share exchange and may qualify for the special regime provided for in share exchanges in Chapter VIII of Title VII of the consolidated text of the Corporate Income Tax Law.
The transaction may be considered a share exchange if the acquiring entity obtains the majority of voting rights through the allocation of new securities to the shareholders. To apply the special regime, the shareholders must reside in Spain or the EU, and the acquiring entity must be a resident in Spain or fall within the scope of Directive 90/434/EEC. Furthermore, the transaction must respond to valid economic reasons and must not have the primary objective of obtaining a tax advantage.
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