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A company held by a family unit has enquired whether its transaction can apply the special merger regime. The DGT indicates this is possible provided commercial requirements are met and the transaction is driven by valid economic motives rather than solely for tax purposes.
Question posed: Whether the described transaction could qualify for the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
To apply the special merger regime, the transaction must comply with the requirements of Law 3/2009 and the provisions of Article 76.1 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. The motives of unifying and simplifying management and enhancing assets may be considered valid pursuant to Article 89.2 of the LIS.
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