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A query was raised regarding whether a total demerger and a merger of several entities can apply the special regime under the Corporate Income Tax Act (LIS). The Directorate General for Taxes (DGT) responds that this is possible provided that commercial requirements are met and the transaction is driven by valid economic motives rather than mere tax advantages.
Question posed: Whether the described operations may qualify for the special tax regime under Chapter VII of Title VII of Corporate Income Tax Law 27/2014, of November 27.
For total demergers, if carried out pursuant to Law 3/2009 and the partners receive shares on a proportional basis, the special regime applies without the requirement that the assets constitute business lines. For mergers, if commercial regulations and Article 76.1.a) of the LIS are complied with, the regime is applicable provided that its primary objective is not tax fraud or evasion. Reasons of rationalization, centralization of assets, and cost reduction are considered valid economic reasons pursuant to Article 89.2 of the LIS.
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