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A company has requested clarification on whether a merger between its subsidiaries can benefit from the tax neutrality regime. The Directorate General for Taxes (DGT) has ruled that this is possible provided the operation meets the requirements of the Non-Resident Income Tax Law (TRLIS) and is conducted for valid economic reasons rather than for the purpose of obtaining a tax advantage.
Cuestión planteada Si la operación descrita puede acogerse al régimen de neutralidad fiscal establecido en el capítulo VIII del título VII del texto refundido de la Ley del Impuesto sobre Sociedades, aprobado por el Real Decreto Legislativo 4/2004, de 5 de marzo.
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