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An agricultural company inquires whether its proposed merger by absorption may apply the special tax regime for reorganizations. The DGT indicates that this is possible if the requirements of the Capital Companies Act and the Corporate Income Tax Act are met, provided that valid economic reasons exist.
Question posed: Whether the special tax regime of Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax is applicable to the proposed transaction.
To apply the special merger regime, the transaction must be carried out within the mercantile sphere pursuant to Law 3/2009 and comply with Article 76.1 of the Corporate Income Tax Act. The regime shall not apply if the primary objective is tax fraud or evasion, or if there are no valid economic reasons such as the restructuring or rationalization of activities. Reasons of structural simplification, cost reduction, and generational succession may be considered valid pursuant to Article 89.2 of the Corporate Income Tax Act.
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