Partner-attended · reply within 24 business hours
Corporate transactions, capital markets and strategic deals.
Independent assessment and rigorous valuation of assets and businesses.
Business reinvention, sustainability and wealth management.
Corporate governance, succession and transformation
International tax planning and cross-border structuring.
Regulatory compliance and tax reporting obligations.
Special regimes for individuals and digital assets.
Tax defense and wealth taxes
Corporate immigration, ICT transfers, investor residency, digital nomad and regularisation.
Employment relations, mobility and regulatory protection.
Protection, compliance and digital resilience
Data protection, DPO and AI regulation
Company formation, contracts, shareholder agreements and corporate operations.
Contracts, dismissals, redundancies and labour court representation.
Insolvency proceedings, fresh start, micro-enterprise procedure and dissolution.
Litigation, arbitration, mediation, IP and real estate law.
Accounting, reporting and outsourced financial management.
Entity management, governance and personnel administration.
Incorporation, incentives and business acceleration.
Risk management, continuity and recovery
New guides on the latest Spanish tax and immigration developments.
Practical tools for informed decision-making.
A parent company has enquired whether an acquisition of shares can qualify for the special share exchange regime. The DGT indicates this is possible provided that a majority of voting rights are obtained, residency requirements are met, and the transaction is driven by valid economic reasons rather than purely tax advantages.
Question posed: Whether the described operation may benefit from the special tax regime of Chapter VIII, Title VII of the Consolidated Text of the Corporate Income Tax Law approved by Royal Legislative Decree 4/2004, of March 5.
To apply the special regime for the exchange of securities, the entity must acquire holdings that allow it to obtain the majority of voting rights. The residency requirements for the partners and the acquiring entity provided for in Article 87 of the TRLIS must be met. Furthermore, the operation must not have fraud or tax evasion as its main objective, and must be based on valid economic reasons such as the restructuring or rationalization of activities.
What is published here, applied to a company or a specific case. The first meeting is free.
Partner-attended · reply within 24 business hours
Quick message
We reply within 24 business hours. Confidential handling guaranteed.
Google Meet
Direct slot with the partner. Complimentary consultation · no commitment · cancel up to 24h in advance.
Loading availability…
We're fully booked for the next 14 days.
That's a good sign, and we won't leave you hanging.
Request callback
Tell us a time window and a phone number. A partner will call you back during the chosen slot.
< 24 h reply · direct with partner
Have a specific question? Tell us your situation in a sentence or two: a partner will reply within 24 business hours.
Complimentary 30-minute meeting with the partner responsible for your area. Google Meet or in person. Cancel up to 24h in advance.
Loading availability…
We're fully booked for the next 14 days.
That's a good sign, and we won't leave you hanging.
Tell us your preferred time slot and a phone number. A partner will call you back, with no hold queues and no gatekeepers.
We use our own and third-party cookies to improve your experience. More information
Essential for the website to function. Cannot be disabled.
Help us understand how you use the site to improve it.
Enable relevant content and advertising.