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Companies A and B, belonging to the same group, have enquired whether their merger by absorption can apply the special regime of the Corporate Income Tax Act (LIS) and if their objectives are economic in nature. The Directorate General for Tax (DGT) indicates that the operation may qualify for said regime if it meets commercial and tax requirements, and considers the stated reasons to be valid.
Question raised: Whether the described transaction may qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax and whether valid economic reasons exist.
To apply the special merger regime, the transaction must be carried out within a commercial scope pursuant to Law 3/2009 and comply with Article 76.1 of the LIS. Furthermore, its primary objective must not be tax fraud or evasion, but rather respond to valid economic reasons such as the restructuring or rationalization of activities. The objectives of eliminating duplicate structures, strengthening the economic position, and optimizing financial relationships are considered valid economic reasons pursuant to Article 89.2 of the LIS.
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