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An inquiring entity asks whether the absorption of a subsidiary can qualify for the special merger regime based on economic motives. The DGT indicates that it must comply with commercial regulations and Corporate Tax requirements, provided its primary purpose is not fraud or tax advantage.
Question posed: 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, on the grounds that valid economic reasons are present.
To apply the special merger regime, the transaction must be carried out in a commercial context pursuant to Law 3/2009 and comply with the terms of Article 76.1 of the LIS. 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. Reasons of commercial, productive, or technical efficiency and management simplification could be considered valid, although their classification depends on the actual facts.
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