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A query was raised regarding whether a merger by absorption between two entities with identical shareholder structures can apply the special Corporate Income Tax (CIT) regime and if valid economic reasons exist. The Directorate General for Taxes (DGT) ruled that the operation may qualify for this regime if carried out under the Structural Changes Law and complies with Article 76.1 of the CIT Act, provided its primary purpose is not tax evasion or tax advantage.
This ruling clarifies the requirements for tax neutrality in mergers, emphasizing that compliance with commercial law and the presence of genuine economic motives are essential to prevent the misuse of special tax regimes.
The tax team reviews your specific situation.
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