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A real estate developer has enquired whether its merger operation can apply the special Corporate Income Tax regime and what constitutes valid economic reasons. The DGT indicates that the operation could qualify for the regime if it meets commercial and tax requirements, provided its primary purpose is not to obtain a tax advantage.
Question raised QUESTION RAISED: 1) Whether the described transaction 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, and whether valid economic reasons exist.
The transaction may qualify for the special regime if it is carried out under Law 3/2009 and complies with Article 76.1.a) of the LIS. The alleged economic reasons could be valid if the merger seeks the restructuring or rationalization of activities. The fact that the absorbing company has negative tax bases does not invalidate the regime, provided that the predominant purpose is not their exploitation and the activities are maintained.
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