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The applicant inquired whether a corporate restructuring could qualify for the special merger regime and if its underlying motives were valid. The DGT indicated that if the transaction meets the requirements of the TRLIS and is conducted for economic rather than purely tax-driven reasons, it may benefit from said regime.
Cuestión planteada Si la operación de reestructuración planteada podría acogerse al régimen fiscal especial regulado en el capítulo VIII del título VII del texto refundido de la Ley del Impuesto sobre Sociedades. Y si los motivos económicos pueden considerarse como válidos a efectos de la aplicación del citado régimen especial.
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