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A query is made as to whether a merger by absorption of two companies by a holding company may apply the special Corporate Income Tax regime. The DGT indicates that this is possible if the requirements of the Business Corporations Law and the Corporate Income Tax Law are met, provided that its primary purpose is not tax fraud or evasion.
Question raised 1) Whether the described transaction may qualify for the special tax regime of Chapter VII of Title VII of Corporate Income Tax Law 27/2014, of November 27.
To apply the special regime of the Corporate Income Tax Law, the transaction must be carried out within the commercial sphere pursuant to Law 3/2009 and comply with the requirements of Articles 76.1.a) and c) of the Corporate Income Tax Law. Furthermore, it must respond to valid economic reasons, such as the restructuring or rationalization of activities, and not have tax advantage as its primary objective. The proposed reasons of solvency improvement and corporate simplification are considered economically valid.
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