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The taxpayer asks whether a merger operation can apply the special tax regime under the TRLIS. The DGT rules that it is possible if the operation meets the requirements of Article 83.1 of the TRLIS and is carried out for valid economic reasons pursuant to Article 96.2.
Question posed: Whether the described transaction may qualify for the special tax regime of Chapter VIII, Title VII of the Recast Text of the Corporate Income Tax Law approved by Royal Legislative Decree 4/2004, of March 5.
To apply the special merger regime, the transaction must be carried out in a commercial context under Law 3/2009 and comply with Article 83.1 of the TRLIS. The regime shall not apply if the primary objective is tax fraud or evasion, or if it lacks valid economic reasons. The existence of pending negative tax bases to be offset does not in itself invalidate the regime, provided that the activities are maintained and the financial situation of the resulting activities is improved.
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