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A holding company queries whether its merger activities may apply the special tax regime. The DGT responds that eligibility is possible if the LIS and Structural Modifications Law requirements are met and the merger has genuine economic motives rather than purely fiscal benefits.
Question posed: Whether the described operations could qualify for the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
To apply the special regime, the merger must be carried out within the commercial sphere pursuant to Law 3/2009 and comply with the requirements of Articles 76.1.a) and c) of the LIS. The existence of negative tax bases does not prevent the regime if the operation seeks to strengthen the financial situation of the activities and its preponderant purpose is not the exploitation of said bases. The alleged motives could be economically valid provided that the activities are maintained and do not form part of a liquidation plan.
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