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A query was raised regarding whether a merger by absorption can qualify for the special regime for European companies and if the stated grounds are valid. The Directorate General for Taxes (DGT) ruled that the special regime is applicable provided the requirements of the Corporate Income Tax Law are met and the operation serves economic purposes rather than being solely for tax advantages.
Question posed: Whether the application of the special regime of Chapter VIII of Title VII of the consolidated text of the Corporate Income Tax Law is appropriate for the proposed operation. And whether the alleged reasons are considered economically valid for these purposes.
To benefit from the special regime for mergers, demergers, and other operations, the operation must comply with the terms of Article 83.1 of the TRLIS and be carried out under the Law on Structural Modifications. Article 96.2 of the TRLIS prevents the use of this regime if the primary objective is tax fraud or evasion. Valid economic reasons, such as the rationalization of activities, allow for tax neutrality. The existence of negative tax bases does not invalidate the regime if it is not the preponderant purpose of the operation.
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