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A query is made as to whether a merger operation could apply the special tax regime of the Corporate Income Tax Law. The DGT indicates that it must comply with commercial regulations and the requirements of the LIS, provided that its primary purpose is not fraud or tax advantage.
Question posed: Whether the aforementioned special merger operation could qualify for the special tax regime regulated in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
To apply the special regime, the operation must be carried out within the commercial sphere pursuant to Law 3/2009 and comply with Article 76.1 of the LIS. The regime shall not apply if the primary objective is fraud or tax evasion, or if it lacks valid economic reasons such as the restructuring or rationalization of activities. The economic reasons alleged by the taxpayer, such as the attainment of economies of scale and synergies, may be considered valid pursuant to Article 89.2 of the LIS.
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