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The consultant asks whether a reorganisation can apply the special merger regime of the Corporate Income Tax. The DGT states that it must comply with commercial regulations and the requirements of article 76.1.a) of the LIS, in addition to not having fraud or tax advantage as its primary objective.
Question posed: Whether the described transaction could benefit from the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
If the transaction is carried out under Law 3/2009 and complies with Article 76.1.a of the LIS, the special regime could apply. Resident partners in Spain would not include income from the attribution of values and would maintain their tax values. However, Article 89.2 of the LIS prevents the regime if the primary objective is tax advantage without valid economic reasons. The reasons stated by the applicant could be valid, but their classification depends on the verification of the facts.
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