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The applicant asks whether a merger between companies within a business group can qualify for the special regime of Corporate Income Tax. The DGT indicates that, provided the operation complies with commercial regulations and the requirements of Article 76.1.a) of the LIS, it could benefit from said regime as long as valid economic reasons exist.
Question posed: Whether the described operation could benefit from the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
Para aplicar el régimen especial de fusiones, la operación debe cumplir la normativa mercantil de la Ley 3/2009 y los requisitos del artículo 76.1.a) de la LIS. No se aplicará el régimen si el objetivo principal es el fraude o la evasión fiscal, o si no existen motivos económicos válidos como la reestructuración o racionalización de actividades. Los motivos de optimización de recursos y simplificación de gestión pueden considerarse válidos según el artículo 89.2 de la LIS.
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