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A query is made as to whether an improper merger, where an entity absorbs another entity in which it holds a full interest, may apply the special regime of the Corporate Income Tax Act (LIS). The DGT responds that it is possible if the operation complies with commercial legislation and is carried out for valid economic reasons and not for the purpose of obtaining a tax advantage.
Question posed: Whether the described operation may qualify for the special tax regime of Chapter VII of Title VII of Corporate Income Tax Law 27/2014, of November 27.
The operation may qualify for the special regime of Chapter VII of Title VII of the LIS provided that it meets the merger requirements established in commercial legislation. Resident partners in Spain shall not include in their tax base the income from the attribution of values from the acquiring entity, which shall be valued at the tax value of the assets transferred. To apply this regime, the operation must not have fraud or tax evasion as its primary objective, and must respond to valid economic reasons such as the restructuring or rationalization of activities.
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