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A query is made as to whether an exchange of shares and a merger by absorption of wholly-owned entities may qualify for the special tax regime. The DGT responds that this is possible provided that the legal requirements are met and the primary purpose of the operation is not tax fraud or tax advantage.
Question posed: Whether the described operations of exchange of shares and improper merger may qualify for the special tax regime under Chapter VII of Title VII of the Corporate Tax Law 27/2014, of November 27.
The exchange of shares may apply the special regime if the entity acquires the majority of voting rights and the requirements of Article 80 of the LIS are met. The merger by absorption of a wholly-owned entity may qualify for the regime if it complies with commercial regulations and does not have tax advantage as its primary objective. Reasons of management simplification and generational succession are considered valid economic reasons, and the existence of minor negative tax bases does not, in itself, invalidate the regime.
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