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A company has requested a ruling on whether its merger with two other entities qualifies for the special Corporate Tax regime and if the transaction is subject to VAT. The DGT indicates that the merger may be tax-neutral provided there are valid economic reasons, though it warns that the transfer of assets could be subject to VAT if it does not constitute an autonomous economic unit.
Question raised 1) 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 of the TRLIS, the transaction must be carried out within a commercial scope and comply with Article 83.1. The existence of negative tax bases does not prevent the regime, provided that the primary objective is economic efficiency and not mere tax advantage. Regarding VAT, the transfer shall not be subject to tax if the transferred elements constitute an autonomous economic unit capable of carrying out an activity by itself.
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