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A company has enquired whether the merger of a wholly-owned subsidiary can qualify for the special tax regime. The DGT has ruled that it is not applicable, as the transaction appears to seek the offsetting of tax losses without valid economic reasons.
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 respond to valid economic motives such as the restructuring or rationalization of activities. If the primary objective of the transaction is tax advantage, such as the offsetting of negative tax bases of an inactive entity, said regime cannot be applied. In this case, as there is no activity in the entities nor improvement of the equity structure, it is considered that the purpose is merely fiscal.
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