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A query is made as to whether a merger by absorption and a non-monetary contribution of equity interests may apply the special Corporate Income Tax regime. The DGT indicates that this is possible if the legal requirements are met and the operation does not have the primary purpose of fraud or tax advantage.
Question posed: Whether the described operations of merger and non-monetary contribution of interests may qualify for the special tax regime of Chapter VII of Title VII of the Corporate Income Tax Law 27/2014, of November 27.
Regarding the merger, if it is carried out within the commercial sphere pursuant to Law 3/2009 and complies with Article 76.1 of the LIS, it may qualify for the special regime. In the case of a non-monetary contribution of interests by natural persons, it is required that the receiving entity be a resident, that the contributor retains at least 5% of the equity after the operation, and that the interests have been held uninterruptedly during the previous year. Furthermore, the operation must respond to valid economic reasons and must not have the primary objective of tax advantage or fraud.
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