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A company has requested clarification on whether an acquisition of shares can qualify for the special regime for the exchange of securities. The DGT states that this is possible provided that residency and majority voting rights requirements are met, and that the primary purpose of the transaction is not tax fraud or evasion.
Question posed: Whether the described operation may qualify for the special tax regime of Chapter VIII, Title VII of the Recast 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 acquiring entity must obtain the majority of the voting rights of the participated entity. The residency requirements for the partners and the acquiring entity provided for in Article 87.1 of the TRLIS must be met. Furthermore, the operation must not have the primary objective of tax fraud or evasion, and must respond to valid economic motives such as the restructuring or rationalization of activities.
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