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A real estate development company inquires whether its merger by absorption with another entity may apply the special Corporate Income Tax regime. The DGT responds that it is possible if the transaction is carried out in a commercial context and responds to valid economic reasons and not solely to a tax advantage.
Question posed: Whether the aforementioned transaction may qualify for the special tax regime under Chapter VII of Title VII of the LIS.
To apply the special merger regime, the transaction must be carried out in a commercial context pursuant to Law 3/2009 and comply with Article 76.1 of the LIS. Furthermore, its primary objective must not be tax fraud or evasion, requiring valid economic reasons such as the restructuring or rationalization of activities. The alleged reasons of simplification, coordinated management, and financial capacity are considered economically valid.
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