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The applicant asks whether a projected merger can qualify for the special merger regime and if its motives are economically valid. The DGT rules that if the transaction meets the requirements of the TRLIS and is carried out under the Structural Changes Law, said regime may apply provided its primary purpose is not fraud or tax advantage.
Question posed: Whether the application of the special regime of Chapter VIII of Title VII of the consolidated text of the Corporate Income Tax Law is appropriate for the proposed merger. And whether the alleged reasons are considered economically valid for these purposes.
To benefit from the special merger regime, the operation must comply with the provisions of Article 83.1 of the TRLIS and be carried out within the commercial sphere pursuant to Law 3/2009. Valid economic reasons, such as the improvement of the financial structure or the simplification of obligations, allow for the application of the regime, even if the absorbed company has negative tax bases. However, the application of the regime requires opting for it by notifying the Administration within a period of three months from the registration of the deed.
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