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A Spanish entity belonging to a tax consolidation group has enquired whether a series of mergers may qualify for the special merger regime and if their underlying motives are considered valid. The DGT has ruled that if the transactions meet the requirements of the Structural Changes Law and the Corporate Income Tax Law, and are based on economic reasons such as efficiency or cost reduction, they may apply said regime.
Cuestión planteada Si la operación planteada podría acogerse al régimen fiscal especial regulado en el capítulo VII del título VII de la Ley del Impuesto sobre Sociedades. Y si los motivos económicos pueden considerarse como válidos a efectos de la aplicación del citado régimen especial.
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