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A company has enquired whether a group merger operation can apply the special Corporate Tax regime and if its motives are economically valid. The DGT responds that, provided the operation meets commercial and tax requirements, it may apply said regime as long as its primary objective is not tax advantage.
Question raised: Application of the special regime of Chapter VIII of Title VII of the consolidated text of the Corporate Income Tax Law to the operation described in point 1. And whether the alleged motives are considered economically valid for these purposes.
The operation may qualify for the special regime if it is carried out under the Structural Changes Law and complies with Article 83.1 of the TRLIS. The alleged motives (unification of management, cost reduction, and competitiveness) are considered economically valid if the purpose is not merely tax-related. The existence of negative tax bases in the absorbed company does not invalidate the regime if the merger strengthens the equity position of the resulting company. The offsetting of said bases shall be subject to the limits of Articles 90 and DT 41 of the TRLIS.
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