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A family business asks whether the fusion of three companies with the same business purpose can benefit from the fiscal neutrality regime and whether negative taxable bases can be offset. The DGT states that if the operation meets commercial and LIS requirements, the regime may apply, allowing the substitution of negative taxable bases.
Question raised 1. Whether the described operation may qualify for the tax neutrality regime, provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax, as well as whether valid economic reasons exist for the purpose of its application.
The merger may qualify for the tax neutrality regime if it meets the requirements of Chapter VII of Title VII of the LIS and its primary objective is not tax fraud or evasion. If this regime is applied, the absorbing company may offset the negative tax bases of the absorbed companies within the limits of article 84 of the LIS. The existence of negative tax bases does not invalidate neutrality if the merger strengthens the activity and is not part of a liquidation plan.
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