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A query was raised regarding whether a merger operation can qualify for the special regime of Corporate Income Tax. The DGT indicates that to do so, it must be carried out under commercial law and meet the requirements of Article 76.1.a) of the LIS, and must not have fraud or tax advantage as its primary purpose.
Question posed: Whether the described operation could qualify for 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 realizarse en el ámbito mercantil según la Ley 3/2009 y cumplir el 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 económicos alegados por la consultante, como la optimización de recursos y reducción de costes, pueden considerarse válidos.
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