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The consultant asks whether a proposed merger can apply for the special merger regime and whether valid economic grounds exist. The DGT states that if the operation complies with the Structural Reform Law and Article 76.1.a) of the LIS, it may qualify for such regime, provided its main objective is not fiscal advantage.
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 motives exist.
To apply the special regime, the transaction must be carried out within the commercial sphere pursuant to Law 3/2009 and comply with Article 76.1.a) of the LIS. Furthermore, pursuant to Article 89.2 of the LIS, the transaction must not have the primary objective of tax fraud or evasion, but must instead respond to valid economic motives such as the restructuring or rationalization of activities. Motives of structural simplification and balance sheet strengthening could be considered valid, although their application depends on the reality of the facts.
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