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A query was raised regarding whether a merger and a partial demerger of activities can benefit from the special tax regime under the Corporate Income Tax Act (LIS). The Directorate General for Taxes (DGT) ruled that this is possible provided the requirements of the Structural Changes Act and the LIS are met, and the transaction is supported by valid economic reasons.
Question raised 1) Whether the described operations may qualify for the special tax regime of Chapter VII of Title VII of the Corporate Income Tax Law 27/2014, of November 27.
For the merger, the operation must be carried out within the commercial sphere pursuant to Law 3/2009 and comply with articles 76.1.a) and c) of the LIS. In the partial demerger, the segregated assets must constitute an autonomous economic unit (branch of activity) and another branch of activity or majority holdings must be maintained in the transferring company. Furthermore, the operation must not have fraud or tax evasion as its primary objective, but rather valid economic motives such as restructuring or rationalization.
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