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A family company inquires whether the acquisition of shares to obtain a majority of voting rights may qualify for the special share exchange regime. The DGT indicates that this is possible if the legal requirements are met and the primary purpose is not fraud or tax advantage.
Question posed: Whether the described transaction may qualify for the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax, and, where applicable, what the treatment would be for the purposes of Personal Income Tax and the Tax on Onerous Asset Transfers and Documented Legal Acts.
The transaction may qualify for the special share exchange regime if the entity acquires shares that allow it to obtain a majority of voting rights and the requirements of Article 80 of the CIT are met. However, application requires that the transaction does not have the primary objective of fraud or tax evasion, but rather valid economic motives such as the restructuring or rationalization of activities. Regarding the ITP/AJD, as it is a restructuring transaction, it is not subject to the corporate transactions modality nor is it subject to the modalities of onerous asset transfers or documented legal acts.
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