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A query was raised regarding whether a merger operation can apply the special tax regime under the Corporate Income Tax Act. The DGT ruled that it is possible provided the requirements of Article 76.1.c) are met and the primary purpose of the operation is not tax fraud or evasion.
Question posed: Whether the described transaction may qualify for the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
To apply the special regime, the transaction must comply with the requirements of Article 76.1.c) of the LIS and have legal effects analogous to a Spanish commercial merger. Furthermore, pursuant to Article 89.2, the transaction must not have fraud or tax evasion as its primary objective, and must be based on valid economic reasons rather than the mere pursuit of a tax advantage. Economic validity is presumed if fraud or tax evasion is not the primary objective.
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