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A family group inquires whether the contribution of shares from several companies to a holding company may qualify for the special share exchange regime. The DGT responds that it is possible if the residency and majority voting rights requirements are met, and that the stated reorganization motives are economically valid.
Question posed: Whether the proposed operation may qualify for the special regime under Chapter VII of Title VII of the Corporate Income Tax Act, and whether the stated motives are considered economically valid for these purposes.
To apply the share exchange regime (Art. 76.5 CIT Act), the entity must acquire the majority of voting rights and meet the residency requirements for both the partners and the beneficiary entity (Art. 80.1 CIT Act). The regime shall not apply if the principal objective of the operation is tax fraud or evasion without valid economic reasons (Art. 89.2 CIT Act). The motives of concentrating holdings, improving financing, simplifying succession, and stabilizing management are considered economically valid.
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