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A company asks whether a merger can apply to the special corporate tax regime and if it is driven by valid economic motives. The DGT states that if the merger meets commercial and fiscal requirements and is based on valid economic grounds, it may qualify for such regime.
Question posed - Whether the described merger 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.a) of the LIS. 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. Reasons of simplification, unification of assets, and cost reduction could be considered valid, although their classification is a matter of fact.
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