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The applicant asks whether a merger operation can apply the special regime for Corporate Tax. The DGT indicates that if the merger meets commercial requirements and has valid economic reasons, it may apply said regime.
Question raised 1) Whether the described transaction may benefit from the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
To benefit from the special merger regime under the LIS, the transaction must be carried out in accordance with the Law on Structural Modifications and comply with Article 76.1. The application of the regime requires that the transaction's primary objective is not tax fraud or evasion, but rather valid economic reasons such as the restructuring or rationalization of activities. In this case, resolving cash flow tensions and saving management costs are considered valid economic reasons.
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