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A query was raised regarding whether a merger between three companies within the same family group could benefit from the special tax regime. The DGT indicates that to qualify, the operation must meet the requirements of the Structural Changes Act and Article 83.1 of the TRLIS, and its primary purpose must not be tax advantage.
Question posed: Whether the described transaction may qualify for the special tax regime of Chapter VIII, Title VII of the Recast Text of the Corporate Income Tax Law approved by Royal Legislative Decree 4/2004, of March 5.
To apply the special merger regime, the transaction must be carried out within the commercial sphere pursuant to Law 3/2009 and comply with Article 83.1 of the TRLIS. Furthermore, pursuant to Article 96.2 of the TRLIS, the transaction must respond to valid economic motives, such as the restructuring or rationalization of activities, and must not have the primary objective of tax fraud or evasion. The alleged motives of management simplification and rationalization may be considered valid, subject to administrative verification of all circumstances.
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