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A query is made as to whether a merger by absorption between two companies may apply the special regime of Corporate Income Tax. The DGT indicates that it must comply with commercial regulations and Article 76.1 of the LIS, in addition to not having fraud or tax advantage as its primary purpose.
Question posed: Whether the described transaction may qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
To apply the special regime, the transaction must be carried out within the commercial sphere pursuant to Law 3/2009 and comply with Article 76.1 of the LIS. Likewise, according to Article 89.2 of the LIS, the transaction must not have fraud or tax evasion as its main objective, and must be based on valid economic motives such as the restructuring or rationalization of activities. Motives of cost reduction and structural simplification could be considered valid, although their classification depends on the facts.
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