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An entity inquires whether a merger by absorption may apply the special Corporate Income Tax regime and whether valid economic reasons exist. The DGT indicates that if the transaction meets the commercial and Corporate Income Tax requirements, said regime may be applied, provided that its primary purpose is not tax advantage.
Question raised 1) Whether the described transaction could qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax and whether valid economic reasons exist.
If the merger meets the requirements of Article 76.1 of the LIS and is carried out within a commercial scope, it may qualify for the special tax neutrality regime. Income from the cancellation of the participation shall not be integrated if the absorbing company holds at least 5% of the absorbed company. The application of the regime is excluded if the primary objective is tax fraud, tax evasion, or the mere obtaining of a tax advantage without valid economic reasons. Regarding ITPAJD, the transaction shall be not subject to the corporate operations modality and exempt in the modalities of asset transfers and documented legal acts.
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