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A query is made as to whether the merger of two real estate companies held by the same company may apply the special tax regime. The DGT responds that it is possible if commercial regulations and Article 76.1.a) of the LIS are met, provided it is not for the purpose of tax fraud or evasion.
Question posed: Whether the described operation may qualify for the special tax regime under Chapter VII of Title VII of Corporate Income Tax Law 27/2014, of November 27.
To apply the special regime, the operation must be carried out within the commercial sphere pursuant to Law 3/2009 and comply with Article 76.1.a) of the LIS. The alleged economic reasons, such as structural simplification, cost reduction, and improved solvency, are considered valid to prevent the application of Article 89.2 of the LIS. Shareholders resident in Spain shall not include in their tax base the income from the attribution of values, which shall be valued at their tax value.
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