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A query was raised regarding whether a merger operation can qualify for the special regime under the Corporate Tax Act. The DGT ruled that this is possible provided that both commercial and tax requirements are met, and that the operation is driven by economic motives rather than solely for tax advantages.
Question posed: Whether the described operation may benefit from the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27.
Para aplicar el régimen especial, la operación debe cumplir lo dispuesto en la Ley de modificaciones estructurales y en el artículo 76.1.a) de la LIS. La existencia de bases imponibles negativas no impide el régimen si la fusión tiene motivos económicos válidos y no busca principalmente el fraude o la evasión fiscal. Si se aplica este régimen, los socios residentes no integrarán rentas en su base imponible y los valores recibidos mantendrán el valor fiscal de los entregados.
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