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The taxpayer asks whether a merger by absorption of a wholly-owned subsidiary may apply the special regime of the Corporate Income Tax Act (LIS) and whether its motives are valid. The DGT responds that, if the operation meets the commercial and LIS requirements, it may qualify for the regime provided that its primary purpose is not tax advantage.
Question posed: Whether the proposed operation could qualify for the special tax regime regulated in Chapter VII of Title VII of the Corporate Income Tax Act, and whether the economic motives can be considered valid for the purposes of applying the aforementioned special regime.
The operation may qualify for the special regime if it is carried out under the Structural Changes Law and complies with the LIS. The motives of structural simplification and resource optimization are considered economically valid. The fact that the absorbed company has tax loss carryforwards does not invalidate the regime if the operation is carried out between operating companies and does not predominantly seek their utilization. The offsetting of said tax losses shall be subject to the limits of Articles 84 and DT 16th of the LIS.
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