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A query was raised regarding whether a merger of holding companies intended to centralise management and optimise resources can qualify for the special merger regime. The Directorate General for Taxes (DGT) ruled that if the transaction is driven by valid economic reasons and is not primarily aimed at fraud or tax evasion, it may qualify for said regime.
Question posed: Whether the proposed transaction may qualify for the special regime of Chapter VII of Title VII of the Corporate Income Tax Law, and whether the reasons stated are considered economically valid for these purposes.
To apply the special merger regime (Chapter VII of Title VII of the LIS), the transaction must be carried out within a commercial scope and comply with the requirements of the LIS. The existence of negative tax bases or pending deductions does not invalidate the regime if the predominant purpose is not their exploitation, but rather the rationalization of activities or the optimization of resources. The motives of structural simplification, centralization of decisions, and improvement of financial solvency are considered economically valid.
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