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A company has enquired whether the absorption of an inactive company qualifies for the special merger regime and if valid economic reasons exist. The Directorate General of Taxes (DGT) indicates that if the requirements of the Structural Changes Act and the Corporate Tax Act are met, and the purpose is not merely tax advantage, the operation may apply said regime.
Question raised 1) Whether the described operation 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 aplicar el régimen especial, la operación debe realizarse en el ámbito mercantil según la Ley 3/2009 y cumplir el artículo 76.1.c) de la LIS. No se aplicará el régimen si el objetivo principal es el fraude o la evasión fiscal, o si carece de motivos económicos válidos como la reestructuración o racionalización de actividades. Los motivos de simplificación estructural, ahorro de costes y mejora de solvencia pueden considerarse válidos, siempre que la operación no busque únicamente aprovechar bases imponibles negativas o créditos fiscales.
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