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The consultant asks whether an acquisition to establish a holding company may qualify for the special exchange regime. The DGT responds that it is possible if a majority of voting rights is obtained, the requirements of Article 80 of the LIS are met, and the operation is not primarily aimed at fraud or tax advantage.
Question posed: Whether the described operation 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.
To apply the special regime for the exchange of securities, the entity must acquire holdings that allow it to obtain the majority of voting rights and comply with the requirements of Article 80 of the LIS. Furthermore, 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 motives of centralizing decisions and leveraging synergies may be considered valid, subject to administrative verification.
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