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A query was raised regarding whether a merger by absorption can qualify for the special Corporate Tax regime if the absorbed company holds tax loss carryforwards, and whether a subsequent capital reduction would affect the validity of the transaction. The DGT indicates that the existence of tax losses does not preclude the regime if there are genuine economic motives; however, a subsequent treasury share acquisition and capital reduction could contradict the original business purposes of the merger.
Cuestión planteada
Para aplicar el régimen especial de fusiones, la operación debe realizarse por motivos económicos válidos y no con el principal objetivo de fraude o evasión fiscal. La existencia de bases imponibles negativas no invalida el régimen si se mantienen las actividades y la operación no tiene como finalidad preponderante su aprovechamiento. No obstante, una posterior adquisición de autocartera y reducción de capital podría contradecir el motivo económico de aumentar el patrimonio para inversión.
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