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A real estate leasing company inquired whether it could benefit from the special merger regime under Corporate Income Tax. The DGT ruled that this is possible provided the transaction meets commercial requirements and is driven by valid economic motives, such as debt reduction or management simplification.
Question raised: Whether the special regime provided for in Articles 83 to 98 of the consolidated text of the Corporate Income Tax Law is applicable.
To apply the special merger regime, the operation must comply with the terms of Article 83.1 of the TRLIS and be carried out under the Structural Changes Law. The regime shall not apply if the primary objective is tax fraud or evasion or if it lacks valid economic reasons. The reasons alleged by the taxpayer are considered economically valid. The negative tax bases of the absorbed company may be offset in the acquiring company within the limits of Article 90.3 of the TRLIS.
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