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A holding company inquires whether the merger of its solar energy operating subsidiaries may apply the special Corporate Income Tax regime and whether valid economic reasons exist. The DGT responds that, provided commercial and tax requirements are met, and the reasons are the rationalization and improvement of management, said regime may be applied and negative tax bases shall be subrogated.
Question raised 1. Whether the described operations may qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax and whether valid economic reasons exist.
Merger operations may qualify for the special regime of the Corporate Income Tax Act if they are carried out within the commercial sphere pursuant to Law 3/2009 and comply with the tax regulation requirements. The reasons of rationalization of activities and improvement of management are considered valid economic reasons, preventing the existence of negative tax bases from invalidating the regime. Regarding Transfer Tax and Stamp Duty, restructuring operations are exempt, and the transfer of securities in mergers is not affected by the anti-avoidance rule of the Securities Market Law as it involves the primary market and assets assigned to business activity.
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