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The DGT confirms that an absorption merger may benefit from the special tax neutrality regime if it meets commercial requirements and Article 76.1(a) of the LIS, provided its main objective is not tax fraud or evasion.
Question posed: Whether the merger by absorption operation described can be carried out under the Special Regime for mergers, demergers, asset contributions, and exchange of securities established in Title VII, Chapter VII of Law 27/2021, of November 27, on Corporate Income Tax.
If the transaction is carried out within a commercial scope and complies with Article 76.1 a) of the LIS, it may benefit from the tax neutrality regime. This implies that income from transfers shall not be included in the tax base and the values and seniority of the assets shall be maintained. The absorbing company would be subrogated into the negative tax bases within the limits of the law. The regime shall not apply if the primary objective is tax fraud or evasion or if it lacks valid economic reasons.
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