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A company resident in common territory intends to absorb a company subject to Navarrese regional regulations. The DGT analyzes whether the merger may qualify for the special restructuring regime and whether the alleged reasons are economically valid.
Question posed: Whether the application of the special regime of Chapter VIII of Title VII of the Recast Text of the Corporate Income Tax Law is appropriate for the proposed operation. And whether the alleged reasons are considered economically valid for these purposes.
If the merger is carried out in a commercial context and complies with the terms of Article 83.1 of the TRLIS, it may qualify for the special restructuring regime. The reasons alleged for the operation are considered economically valid pursuant to Article 96.2 of the TRLIS. The existence of tax loss carryforwards in the absorbed company does not prevent the application of the regime, although the compensation by the absorbing company shall be subject to the limits of Articles 90 of the TRLIS and DT 41st.
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