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A company asks whether a reverse merger between a parent and its subsidiary can apply the tax neutrality regime. The DGT responds that it is possible as long as the requirements of the LIS are met and the primary objective is not fraud or tax evasion.
Cuestión planteada
Si la fusión cumple los requisitos del artículo 76.1 de la LIS, se aplicará el régimen de neutralidad fiscal. Esto implica que la sociedad transmitente no integrará rentas por la transmisión y la adquirente mantendrá los valores y antigüedad de los bienes recibidos. Los socios residentes no integrarán rentas por el canje y valorarán los nuevos valores por el valor fiscal de los entregados. No obstante, el régimen no se aplicará si el objetivo principal es el fraude o la evasión fiscal.
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