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A query was made regarding whether a securities exchange and a merger can qualify for the special regime of Corporate Income Tax. The DGT concludes that this is possible provided that legal requirements are met and the transaction is driven by valid economic reasons rather than a purely tax-driven purpose.
Question raised 1) Whether the described exchange of shares and merger operations could 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.
Para el canje de valores, la entidad debe adquirir participaciones que le permitan obtener la mayoría de derechos de voto y cumplir el artículo 80 de la LIS. En la fusión, la operación debe realizarse en el ámbito mercantil según la Ley 3/2009 y cumplir la LIS. En ambos casos, la operación no debe tener como principal objetivo el fraude o la evasión fiscal, requiriéndose motivos económicos válidos como la reestructuración o racionalización de actividades.
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