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A company has enquired whether a merger by absorption and a contribution of assets qualify for the special regime under the Corporate Tax Act (LIS). The Directorate General for Taxes (DGT) has ruled that the non-monetary contribution does not meet the requirements because the properties are not tied to economic activities.
Question posed: Whether the described operations may benefit from the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax and whether valid economic reasons exist.
Para que una fusión se acoja al régimen especial, debe realizarse en el ámbito mercantil según la Ley 3/2009 y cumplir el artículo 76.1 de la LIS. En el caso de aportaciones no dinerarias, el artículo 87.1 de la LIS exige que los elementos aportados estén afectos a actividades económicas. Si no se cumple este requisito, no será de aplicación el régimen especial del Capítulo VII del Título VII de la LIS.
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