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A query was raised regarding whether the merger of two companies can apply the special Corporate Tax regime and if valid economic reasons exist. The DGT indicates that to apply this regime, the operation must be carried out under the Structural Changes Law and comply with Article 76.1 of the Corporate Tax Act, and must not have the primary purpose of tax fraud or evasion.
Question posed: Whether the described transaction may benefit from the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax and whether valid economic reasons exist.
To benefit from the special merger regime, the transaction must be carried out within the commercial sphere pursuant to Law 3/2009 and comply with the requirements of Article 76.1 of the LIS. Likewise, pursuant to Article 89.2 of the LIS, the regime shall not apply if the primary objective is tax fraud or evasion. The reasons of centralization of activity, simplification of structure, joint management, improvement of financial capacity, and cost reduction could be considered valid economic reasons, although their validation depends on the specific facts.
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