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A query was raised regarding whether a merger by absorption followed by a total demerger can qualify for the special Corporate Income Tax regime. The Directorate General for Taxes (DGT) indicates this is possible provided the requirements of the Corporate Income Tax Act and the Structural Changes Act are met, and the transaction is driven by valid economic reasons rather than being solely for tax purposes.
Cuestión planteada
Para aplicar el régimen especial, la fusión y la escisión deben cumplir los requisitos de la LIS y de la Ley 3/2009. En la escisión, si se mantiene la proporcionalidad de las participaciones, no es necesario que los patrimonios constituyan ramas de actividad. La existencia de bases imponibles negativas no impide el régimen especial, siempre que el aprovechamiento de estas no sea la finalidad preponderante y se respeten los límites del artículo 84 de la LIS.
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