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A real estate company has enquired whether its merger by absorption with another entity within the same family group can apply the special Corporate Tax regime. The DGT indicates that it must comply with commercial regulations and Article 76.1 of the LIS, and must not have fraud or tax advantage as its primary purpose.
Question posed: Whether the described transaction 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 and whether valid economic reasons exist.
To apply the special merger regime, the transaction must be carried out within a commercial scope pursuant to Law 3/2009 and comply with Article 76.1 of the LIS. Furthermore, pursuant to Article 89.2 of the LIS, the transaction must not have fraud or tax evasion as its primary objective. Reasons of administrative simplification and greater financial stability could be considered economically valid, although this depends on the verification of the facts.
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