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A query was raised regarding whether a merger between two consultancy firms could qualify for the special Corporate Tax regime and if the economic justifications provided are valid. The Directorate-General for Taxes (DGT) indicates that, provided commercial regulations and Article 83.1 of the Corporate Tax Law are met, this regime may apply, provided it is not intended for tax fraud or evasion.
Question posed: Whether the proposed restructuring transaction could qualify for the special tax regime regulated in Chapter VIII of Title VII of the consolidated text of the Corporate Income Tax Law. And whether the economic reasons can be considered valid for the purposes of applying the aforementioned special regime.
The transaction may qualify for the special Corporate Income Tax regime if it is carried out within a commercial scope pursuant to Law 3/2009 and complies with Article 83.1 of the TRLIS. The alleged reasons of cost savings and economic rationalization are considered valid, and the existence of negative tax bases does not invalidate the regime if the predominant purpose is not their exploitation. Regarding VAT, the transfer shall not be subject to tax if the elements constitute an autonomous economic unit. For ITP and AJD, the transaction shall be neither subject nor exempt if it is classified as a restructuring under the TRLIS.
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