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An investment management company has enquired whether the merger of Spanish investment funds with Luxembourgish funds can benefit from the special merger regime and if their objectives constitute valid economic reasons. The Directorate General for Taxes (DGT) responds that this is possible provided the requirements of the Corporate Tax Act (LIS) are met and the stated reasons are deemed valid.
Cuestión planteada 1. Si las operaciones mencionadas pueden acogerse al régimen fiscal especial del capítulo VII del título VII de la LIS y si las razones expuestas pueden considerarse como motivos económicos válidos a los efectos de lo previsto en el artículo 89.2 de la LIS.
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