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A query is made as to whether a merger operation between companies within the same group may apply the special regime of the Corporate Income Tax. The DGT responds that it is possible if the requirements of the Companies Act and the LIS are met, and if the operation has valid economic reasons and does not solely seek a tax advantage.
Question posed: Whether the described operation may qualify for the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
To apply the special regime, the operation must comply with commercial regulations and with article 76.1.a) of the LIS. Furthermore, pursuant to article 89.2 of the LIS, the operation must respond to valid economic reasons, such as the restructuring or rationalization of activities, and must not have fraud or tax evasion as its primary objective. The existence of tax loss carryforwards does not prevent the application of the regime if the entities are operational and the purpose is not the exploitation of said losses.
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