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A query was raised regarding whether an improper merger, in which an entity absorbs two other wholly-owned subsidiaries, can benefit from the special tax regime. The DGT ruled that this is possible provided the transaction meets commercial requirements and is driven by valid economic motives beyond mere tax advantages.
Question posed: Whether the described operation may qualify for the special tax regime under Chapter VII of Title VII of the Corporate Income Tax Law 27/2014, of November 27.
The operation may qualify for the special regime of the LIS if it meets the merger requirements established in commercial legislation. To this end, the purpose of the operation must be based on valid economic reasons, such as the restructuring or rationalization of activities, and must not have fraud or tax evasion as its primary objective. The existence of minor tax loss carryforwards does not invalidate the regime if the entities are operational and the merger benefits the activities. If applied, the acquiring entity succeeds to the tax rights and obligations, and the compensation of tax loss carryforwards shall be subject to the limits of Articles 84 and the sixteenth transitional provision of the LIS.
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