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A company asks whether creating a new parent (NEWCO) by contributing shares from three holding companies can qualify for the special value exchange regime. The DGT responds that it is possible if Article 80 of the LIS requirements are met and the transaction has valid economic grounds, not merely tax advantages.
Question raised 1) 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.
The transaction may qualify for the share exchange regime if the new entity acquires the majority of voting rights and the requirements of Article 80 of the LIS are met. The application of the regime requires that the transaction does not have the primary objective of tax fraud or evasion, and must respond to valid economic reasons such as the restructuring or rationalization of activities. The proposed reasons of financing unification and reinvestment simplification are considered economically valid. Likewise, the dividends received by NEWCO will be exempt if it meets the requirements of Article 21 of the LIS.
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