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The inquiry examines whether a merger between related parties can benefit from the special tax regime. The DGT rules that this is possible provided the transaction is conducted for commercial purposes, meets statutory requirements, and is driven by valid economic motives, such as the rationalisation of business activities.
Question raised 1) Whether the aforementioned transaction may qualify for the special tax regime under Chapter VIII of Title VII of the Recast Text of the Corporate Income Tax Law, approved by Royal Legislative Decree 4/2004, of March 5.
To apply the special merger regime, the transaction must be carried out within a commercial scope pursuant to Law 3/2009 and comply with Article 83.1 of the TRLIS. The regime shall not apply if the primary objective is tax fraud or evasion, or if it lacks valid economic reasons. In the case presented, the rationalization of the organization and the unification of systems are considered valid economic reasons.
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