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The DGT confirms that a merger under structural reform law, aimed at business reorganisation or rationalisation, may apply the special tax regime.
Question posed: Whether the described operation meets the legal requirements to qualify for the special regime established in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax, with effects on Corporate Income Tax, Personal Income Tax, and Transfer Tax and Documented Legal Acts Tax.
If the merger is carried out under the Structural Changes Law and complies with Article 76.1.a) of the Corporate Income Tax Law (LIS), it may qualify for the special regime. Partners resident in Spain shall not include in their tax base the income derived from the attribution of values, which shall be valued at their tax value. To avoid the general regime, the operation must respond to valid economic reasons, such as the rationalization of activities, and must not have fraud or tax evasion as its primary objective. Regarding Transfer Tax and Stamp Duty (ITP and AJD), restructuring operations are exempt.
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