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A company asks whether its merger proposal can benefit from the special tax regime for restructurings and whether its economic motives are valid. The DGT states that if the operation complies with commercial law and the LIS and does not primarily aim at fraud or tax advantage, it may qualify for this regime.
Question raised: Whether the proposed transaction could qualify for the special tax regime regulated in Chapter VII of Title VII of the Corporate Income Tax Act, and whether the economic motives can be considered valid for the purposes of applying the aforementioned special regime.
The transaction may qualify for the special merger regime if it is carried out within a commercial scope pursuant to Law 3/2009 and meets the requirements of the Corporate Income Tax Act. The alleged economic motives (efficiency, solvency, simplification) are considered valid provided that the purpose is not merely to obtain a tax advantage. The existence of tax loss carryforwards in the transferring company does not invalidate the regime if the merger strengthens the equity position of the resulting company.
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