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A company enquired whether a merger and a total demerger could qualify for the special regime under the Corporate Tax Act. The DGT ruled that this is possible provided that commercial law requirements are satisfied and the primary purpose is not tax evasion or obtaining an unfair tax advantage.
Question raised: Whether the described merger and total spin-off operations may benefit from the special tax regime under Chapter VII of Title VII of Corporate Income Tax Law 27/2014, of November 27.
For the merger, if carried out under Law 3/2009 and complying with Article 76.1.a) of the LIS, the special regime may apply. In the total spin-off, if it conforms to Article 69 of Law 3/2009 and shares are allocated proportionally, it may also benefit from the regime. However, the regime shall not apply if the operation's primary objective is tax fraud or evasion, or if it lacks valid economic reasons pursuant to Article 89.2 of the LIS.
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