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A company has requested clarification on whether its merger by absorption can qualify for the special tax regime. The DGT has ruled that this is possible provided that commercial regulations are complied with and the transaction is driven by valid economic motives rather than being solely for tax purposes.
Question posed: Whether the proposed restructuring operation may qualify for the special tax regime established in Chapter VIII of Title VII of the consolidated text of the Corporate Income Tax Law, approved by Royal Legislative Decree 4/2004, of March 5.
To apply the special regime, the transaction must be carried out under Law 3/2009 and comply with Article 83.1 of the TRLIS. Furthermore, pursuant to Article 96.2 of the TRLIS, the transaction must respond to valid economic reasons, such as the rationalization of activities, and must not have the primary objective of fraud or tax advantage. The presented reasons of cost savings, structural simplification, and improved solvency are considered economically valid.
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