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The DGT confirms that a merger may apply for the special tax regime under the LIS if it meets commercial and fiscal requirements and is carried out for valid economic reasons, not to obtain tax advantages.
Question posed: Whether the described transaction may qualify for the special tax regime under Chapter VII of Title VII of the Corporate Income Tax Law 27/2014, of November 27.
To apply the special regime, the transaction must comply with the provisions of Law 3/2009 and Article 76.1.a) of the LIS. The existence of valid economic reasons, such as cost reduction or new investments, allows for the use of the regime, even if the absorbed entity has negative tax bases. The acquiring company subrogates into said bases within the limits of Article 84.2 of the LIS.
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