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A computer company asks whether creating a holding company to manage national and international shares may qualify for the special share exchange regime. The DGT confirms this is possible as long as LIS requirements are met and the operation is not primarily aimed at tax fraud or evasion.
Question posed: Whether the described operation may qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax
To apply the special regime for the exchange of shares, the acquiring entity must obtain the majority of the voting rights of the participated entity and comply with the requirements of Article 80.1 of the LIS. Likewise, 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. The mentioned motives of expansion, risk management, improved financing, and administrative simplification may be considered valid pursuant to Article 89.2 of the LIS.
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