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A consulting entity has enquired whether a merger by absorption and a total demerger can qualify for the special tax regime. The DGT indicates that they must comply with both commercial and tax regulations, but warns that the regime will not apply if the primary objective is the exploitation of tax loss carryforwards without valid economic reasons.
Question raised: Whether the proposed operations may qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
For the merger, it must be carried out within the commercial sphere pursuant to Law 3/2009 and comply with Article 76.1 of the LIS. In a total spin-off, if the partners receive shares on a proportional basis, it is not necessary for the assets to constitute business lines. However, the special regime shall not apply if the main objective of the operation is tax fraud or evasion, or if it lacks valid economic reasons pursuant to Article 89.2 of the LIS.
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