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A company has requested a ruling on whether a share exchange operation to create a holding company, followed by a total demerger of its assets, can qualify for the special regime under Corporate Income Tax. The DGT has ruled that this is possible provided that all legal requirements are satisfied and the primary purpose of the operation is not to obtain a tax advantage.
Question raised: Whether the described operations 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.
For the exchange of securities, the entity must acquire the majority of voting rights and comply with the requirements of Article 80 of the LIS. In a total spin-off, if the partners receive shares proportionally, it is not necessary for the assets to constitute business lines. In both cases, the application of the special regime requires that the operation be carried out for valid economic reasons and not for the purpose of fraud or tax evasion.
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