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A query is made as to whether a merger by absorption may apply the special merger regime of Corporate Income Tax. The DGT indicates that for this to occur, it must be carried out under the Law on Structural Modifications and must not have the primary objective of obtaining a tax advantage.
Question posed: Whether the projected merger operation may qualify for the special regime for mergers, spin-offs, asset contributions, and exchange of securities regulated in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax, regarding the valid economic reasons underpinning said merger.
The operation may qualify for the special regime if it is carried out within the commercial sphere pursuant to Law 3/2009 and complies with Article 76.1 of the LIS. The regime shall not apply if the primary objective is tax fraud or evasion, or if there are no valid economic reasons such as the restructuring or rationalization of activities. The assessment of these reasons is a matter of fact to be determined by the auditing bodies according to the circumstances of each case.
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