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A query was raised regarding whether a merger by absorption of a subsidiary can apply the special tax regime and if the stated economic reasons are valid. The DGT ruled that, provided commercial regulations and the requirements of the TRLIS are met, the operation may qualify for said regime.
Question posed: Whether the proposed restructuring transaction could qualify for the special tax regime regulated in Chapter VIII of Title VII of the recast text of the Corporate Income Tax Law. And whether the economic reasons can be considered valid for the purposes of applying the aforementioned special regime.
If the transaction is carried out under Law 3/2009 and complies with Article 83.1 of the TRLIS, the special merger regime may be applied. To this end, the transaction must not have the objective of tax fraud or evasion, but must instead respond to valid economic reasons. The reasons of reducing structural costs, improving solvency, and simplifying administrative management are considered economically valid pursuant to Article 96.2 of the TRLIS.
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