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An individual has enquired whether contributing their share in a Spanish company to an entity in the Netherlands can qualify for the special securities exchange regime. The DGT has ruled that, provided the requirements for residence and majority voting rights are met, the transaction may qualify for this regime as long as its primary purpose is not tax evasion or tax advantage.
Question raised: It is asked whether the proposed restructuring operation could qualify for the special tax regime regulated in Chapter VIII of Title VII of the TRLIS.
The contribution of a share that allows for obtaining the majority of voting rights meets the definition of a share exchange under Article 83.5 of the TRLIS. To apply the special regime, the residency requirements for the shareholders and the acquiring entity must be met pursuant to Article 87.1. However, the regime shall not be applicable if the main purpose of the transaction is tax fraud or evasion, or if it lacks valid economic reasons pursuant to Article 96.2.
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