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A company inquired whether a merger between two fully owned entities by the same shareholder could qualify for the special tax regime. The DGT confirms it is possible without share allocation or capital increase, provided commercial requirements are met and valid economic reasons exist.
Question posed: Whether the described operation may qualify for the special tax regime under Chapter VII of Title VII of Corporate Income Tax Law 27/2014, of November 27.
In mergers between companies wholly owned by the same shareholder, the failure to allocate shares does not prevent the application of the special regime if the shareholder's equity position does not change substantially. The operation must comply with commercial regulations and must not have fraud or tax evasion as its primary objective. Reasons of asset concentration and management simplification are considered valid economic grounds.
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