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A hotel company inquires whether the merger by absorption of a subsidiary may qualify for the special tax regime for mergers and whether its motives are valid. The DGT responds that, if the commercial and LIS requirements are met, the transaction may apply said regime and that the motives for structural rationalization are valid.
Question posed: Whether the special tax regime of Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax is applicable, and whether the economic motives are valid to carry out the merger and whether the tax effects provided for in Articles 76 et seq. of the LIS will apply.
To qualify for the special regime, the transaction must be carried out in a commercial context pursuant to Law 3/2009 and comply with Article 76.1 of the LIS. Shareholders resident in Spain shall not include in their tax base the income from the attribution of values, which shall be valued at their tax value. The absorption of a dependent company does not extinguish the tax group if the parent entity maintains its character. The motives of activity rationalization and cost efficiency are considered valid economic motives under Article 89.2 of the LIS.
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