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A query is made as to whether a reverse merger between two entities may apply the special regime for Corporate Income Tax. The DGT indicates that if the operation meets commercial and tax requirements and has valid economic reasons, said regime may be applied.
Question raised
The operation may qualify for the special regime if it is carried out under Law 3/2009 and complies with Article 76.1.a) of the LIS. The regime shall not apply if the primary objective is tax fraud or evasion, or if it lacks valid economic reasons. The existence of negative tax bases does not invalidate the regime if the activities are maintained and it is not the preponderant purpose of the merger.
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