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A consulting company suggests absorbing its only subsidiary to simplify its structure and reduce costs. The DGT states that the operation may qualify for fiscal neutrality if it meets legal requirements and does not aim primarily at fraud.
Whether the merger operation described is subject to the special tax neutrality regime established in Chapter VII of Title VII, regulated in Articles 76 et seq. of Law 27/2014, of November 27, on Corporate Income Tax, given that the objective is the improvement of administrative and management processes, as well as the reduction of financial costs. Considering that the merger operation meets the requirements for the application of the special tax neutrality regime, could the existence of significant accumulated negative tax bases from previous financial years in both companies (merger and merged) cause a limitation on their offset or, conversely, does the existence of negative tax bases not invalidate the application of the special regime if the motive is economically valid, as is the case here based on all the aforementioned?
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