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The applicant asks whether a series of capital contributions followed by a merger can qualify for the special tax regime for corporate reorganisations. The DGT rules that this is possible provided that legal requirements are satisfied and the primary purpose of the operation is not to obtain a tax advantage.
Question posed: Whether the described transactions may qualify for the special tax regime under Chapter VII of Title VII of the Corporate Income Tax Law, and whether the economic motives presented can be considered valid.
Securities exchange transactions may qualify for the special regime if they allow for the acquisition of the majority of voting rights and comply with residency and tax valuation requirements. Mergers by absorption of wholly owned subsidiaries may also apply this regime if carried out under the Structural Changes Law. The economic motives alleged for the restructuring are considered valid if their predominant purpose is not the exploitation of tax loss carryforwards.
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