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A query is made as to whether a merger operation between entities may apply the special tax regime of the Corporate Income Tax Law. The DGT indicates that it must comply with commercial regulations and must not have fraud or tax advantage as its primary purpose.
Question posed: Whether the described operation may qualify for the special tax regime of Chapter VII of Title VII of the Corporate Income Tax Law 27/2014, of November 27.
To apply the special regime, the operation must be carried out within the commercial sphere pursuant to Law 3/2009 and comply with Article 76.1.a) of the LIS. Furthermore, the regime shall not apply if the primary objective is fraud or tax evasion, or if it lacks valid economic reasons such as the restructuring or rationalization of activities. The rationalization of the corporate structure to reduce management costs is considered a valid economic reason.
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