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The taxpayer asks whether an operation involving the unification of properties and shares can apply the special merger regime for Corporation Tax. The DGT rules that this is possible provided commercial regulations and Article 76.1 of the LIS are complied with, and that valid economic reasons exist rather than the operation being carried out solely for tax advantages.
Cuestión planteada 1º) Si la operación descrita se podría acoger al régimen fiscal especial previsto en el Capítulo VII del Título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades.
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