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The DGT confirms that mergers or share exchanges may qualify for the special regime of Corporate Income Tax, provided legal requirements are met and the primary objective is not fiscal advantage.
Question raised 1) Whether the described operation could qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
For the merger, if carried out within a commercial context and complying with art. 76.1.a) of the LIS, it may qualify for the special regime. In the exchange of securities, if the acquiring entity obtains the majority of voting rights and the requirements of art. 80 LIS are met, this is also possible. However, the regime shall not apply if the primary objective is tax fraud or evasion without valid economic reasons. The existence of negative tax bases does not prevent the application of the regime if the activities are maintained and the financial situation is strengthened.
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