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A company inquires whether a merger transaction may qualify for the special tax regime under Corporate Income Tax. The DGT responds that it is possible if the requirements of the Law on Structural Modifications and Article 76.1.a) of the LIS are met, provided that its primary purpose is not tax fraud or evasion.
Question raised 1) Whether the described transaction may qualify for the special tax regime under Chapter VII of Title VII of the Corporate Income Tax Law 27/2014, of November 27.
To apply the special merger regime, the transaction must be carried out in a commercial context pursuant to Law 3/2009 and comply with Article 76.1.a) of Law 27/2014. Furthermore, it must not have the primary objective of tax fraud or evasion, and must respond to valid economic motives such as the restructuring or rationalization of activities. In this case, the alleged motives of simplification, efficiency, and solvency are considered valid pursuant to Article 89.2 of the LIS.
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