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The consultant asks whether an absorption merger of entity C can apply for the LIS special regime. The DGT states that it may if carried out in accordance with commercial rules under Law 3/2009 and meets LIS requirements, provided it does not have fraud or tax advantage as its primary objective.
Question posed: Whether the described transaction may qualify for the special tax regime under Chapter VII of Title VII of Corporate Income Tax Law 27/2014, of November 27.
To apply the special merger regime, the transaction must be carried out within a commercial scope pursuant to Law 3/2009 and comply with Article 76.1.a) of the LIS. Partners resident in Spain shall not include in their tax base the income derived from the attribution of assets, which shall be valued at the tax value of the assets transferred. The transaction must not have the primary objective of tax fraud or evasion, and must be based on valid economic motives such as the restructuring or rationalization of activities.
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