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The DGT confirms that an absorption merger may benefit from the special regime of fiscal neutrality if it complies with commercial rules and Article 76.1 of the LIS, provided it does not have the primary objective of fraud or obtaining a fiscal advantage without valid economic reasons.
Question posed: Whether the proposed transaction could qualify for the special regime established in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
To apply the tax neutrality regime, the transaction must be carried out in a commercial context pursuant to Royal Decree-Law 5/2023 and comply with Article 76.1 of the LIS. In mergers where the acquirer holds at least a 5% stake in the transferor, income from the cancellation of participation shall not be integrated pursuant to Article 82.1. Resident partners in Spain shall not integrate income from the attribution of values and shall maintain their tax values. This regime shall not apply if the primary objective is tax fraud or evasion, or if it lacks valid economic reasons such as business restructuring.
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