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A query is made as to whether a merger operation may apply the special regime of the Corporate Income Tax Law. The DGT indicates that to do so, it must meet commercial and tax requirements, and its primary objective must not be tax fraud or evasion.
Question posed: Whether the described operation 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 operation must be carried out within the commercial sphere pursuant to Law 3/2009 and comply with Article 76.1 of the LIS. The regime shall not apply if the primary objective is tax fraud or evasion, or if there are no valid economic reasons such as the restructuring or rationalization of activities. Reasons involving resource optimization and cost reduction could be considered valid, although their classification depends on the actual facts.
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