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Consultants ask whether their merger activities meet the conditions for the Special Regime of Corporate Tax. The DGT states that such a regime may apply if commercial requirements are met and the main purpose is not fraud or tax advantage.
Question posed: Whether the projected merger operations, as well as the alleged economic reasons, comply with all the requirements legally provided for to benefit from the special regime of Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
To benefit from the special regime, mergers must be carried out within the commercial sphere pursuant to Law 3/2009 and comply with Article 76.1.c) of the LIS. Resident partners in Spain shall not include in their tax base the income from the attribution of values, which shall be valued at the tax value of the assets delivered. 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 reasons alleged by the taxpayer could be considered economically valid, although this depends on the verification of the facts.
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