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A company has requested clarification on whether a merger by absorption can qualify for the special Corporate Tax regime and if its objectives justify the transaction. The DGT indicates that it must comply with commercial regulations and Article 76.1 of the Corporate Tax Act (LIS), and must not have fraud or tax advantage as its primary purpose.
Question posed: Whether the described transaction may qualify for 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 motives exist.
To apply the special regime, the transaction must be carried out within the commercial sphere pursuant to Law 3/2009 and comply with Article 76.1 of the LIS. Likewise, pursuant to Article 89.2 of the LIS, the transaction must not have fraud or tax evasion as its primary objective. Reasons such as cost savings, financing optimization, and improvement of image before third parties could be considered valid economic motives, although this depends on the verification of the facts.
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