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A holding company has enquired whether a merger by absorption involving four companies can qualify for the special tax merger regime. The DGT stated it cannot make a definitive determination due to insufficient data regarding the absorbing company; however, it noted that the transaction must comply with the Corporate Income Tax Law (LIS) and be driven by genuine economic motives.
Question posed: Whether the merger by absorption of companies A, B, C, and D may qualify for the special tax regime for mergers, demergers, contributions of assets, exchange of securities, and change of registered office of a European Company or a European Cooperative Society from one Member State to another within the European Union, as regulated in Articles 76 et seq. of Law 27/2014, of November 27, on Corporate Income Tax.
To qualify for the special regime, the transaction must be carried out within a commercial scope pursuant to Law 3/2009 and comply with Article 76.1 of the CIT. Furthermore, the regime shall not apply if the primary objective is tax fraud or evasion, or if there are no valid economic reasons such as the restructuring or rationalization of activities. The Administration will assess the reasons for the transaction by considering the circumstances of each specific case.
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