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A query was raised regarding whether a merger by absorption between two entities can apply the special regime under the Corporate Tax Act (LIS). The DGT indicates that it must comply with the Structural Changes Act and Article 76.1 of the LIS, and must not have fraud or tax advantage as its primary purpose.
Cuestión planteada
Para aplicar el régimen especial, la operación debe realizarse en el ámbito mercantil según la Ley 3/2009 y cumplir el artículo 76.1 de la LIS. No se aplicará el régimen si el objetivo principal es el fraude, la evasión o la obtención de una ventaja fiscal sin motivos económicos válidos. Los motivos de racionalización de costes o mejora de estructura podrían ser válidos, aunque su calificación depende de los hechos.
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