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The taxpayer asks whether a merger operation may apply the special tax regime of the Corporate Income Tax. The DGT responds that it is possible if the operation meets the commercial and tax requirements, and is carried out for valid economic reasons and not for the purpose of obtaining a tax advantage.
Question posed: Whether the described operation may qualify for the special tax regime of Chapter VII of Title VII of Corporate Income Tax Law 27/2014, of November 27.
To apply the special merger regime, the operation must comply with the provisions of the Law on Structural Modifications and Article 76.1.a) of the LIS. The existence of negative tax bases does not invalidate the regime if the entities are operational and the purpose is not the exploitation of said bases. Valid economic reasons, such as the rationalization of activities or generational succession, allow for the application of the special regime pursuant to Article 89.2 of the LIS.
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