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An entity transitioning from a real estate investment company to an ordinary commercial company has queried whether it may qualify for the special merger regime. The Directorate-General for Taxes (DGT) has ruled that such a transformation entails the closure of the tax period and that the operation could apply the special regime, provided it meets all commercial and tax requirements and is not primarily intended for tax evasion.
Question posed: Whether the aforementioned operation may qualify for the special tax regime under Chapter VII of Title VII of the LIS and whether the reasons set forth may be considered valid economic motives for the purposes of the provisions of Article 89.2 of the LIS.
La transformación de la forma societaria o modificación del régimen jurídico que suponga un cambio en el tipo de gravamen o régimen tributario exige la conclusión del período impositivo. Si la operación de fusión se realiza bajo la Ley de modificaciones estructurales y cumple el artículo 76.1 de la LIS, puede acogerse al régimen especial. Los motivos de racionalización de actividades, simplificación de estructura y ahorro de costes operativos se consideran motivos económicos válidos según el artículo 89.2 de la LIS.
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