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A query is made as to whether a merger by absorption of five regional companies by their holding company can apply the special Corporate Income Tax regime. The DGT indicates that if the operation meets the commercial requirements and those of Art. 76.1 LIS, and has valid economic reasons, it may use said regime.
Question raised
To apply the special merger regime, the operation must be carried out in a commercial context pursuant to Law 3/2009 and comply with Art. 76.1 of the LIS. The regime shall not apply if the primary objective is tax fraud or evasion, or if there are no valid economic reasons such as the restructuring or rationalization of activities. Reasons such as structural reduction, unification of decision-making, and cost simplification could be considered economically valid, although their assessment depends on the facts.
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