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A company asks whether a textile residual business absorption merger into a real estate company can apply the tax neutrality regime, if economic motives are valid and negative taxable bases are assumed. The DGT explains that if the transaction meets commercial and LIS requirements, the tax neutrality regime applies, allowing assumption of negative taxable bases and non-integration of income.
Question raised
If the merger is carried out within a commercial scope and complies with Article 76.1 a) of the LIS, it may qualify for the tax neutrality regime. The absorbing company S shall be subrogated into the right to offset the negative tax bases of D, subject to the limits of the law. The fact that the absorbed company has negative tax bases does not invalidate the regime if the operation strengthens the activity and is not primarily intended to exploit the tax bases. Reasons of restructuring and cost rationalization are valid to avoid the application of the anti-avoidance clause.
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