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A query was raised regarding whether a merger between two entities can apply the special Corporate Tax regime. The DGT ruled that if the transaction meets commercial and tax requirements, and is conducted for valid economic reasons rather than to obtain a tax advantage, it may qualify for said regime.
Cuestión planteada
Para aplicar el régimen especial de fusiones, la operación debe cumplir los términos del artículo 76.1 de la LIS y realizarse por motivos económicos válidos según el artículo 89.2 de la LIS. La existencia de bases imponibles negativas pendientes de compensar no invalida el régimen si se mantienen las actividades y la finalidad no es preponderantemente aprovechar dichas bases. Los motivos económicos válidos deben ser valorados según los hechos reales de la operación.
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