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A company has enquired whether a share exchange operation may qualify for the special regime under the Corporate Income Tax Act and whether dividends distributed following the exchange would be exempt. The DGT has ruled that this is possible provided that legal requirements are met, there is no tax fraud, and the conditions regarding shareholding and holding periods for dividend exemption are maintained.
Cuestión planteada 1º) Si la operación descrita de canje de valores podría acogerse al régimen fiscal previsto en el Capítulo VII del Título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades.
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