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A construction company has enquired whether a merger operation intended to unify management and reduce costs can apply the special Corporate Tax regime. The DGT has ruled that, provided commercial requirements are met and valid economic reasons exist, the special regime may be applied, thereby avoiding the accrual of Wealth Tax, Transfer Duty, or Stamp Duty.
Question raised 1) Whether the described transaction could qualify for the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
The transaction may qualify for the special merger regime if carried out under the Structural Changes Law and complies with Article 76.1.b) of the Corporate Income Tax Law (LIS). The reasons of management unification and cost savings are considered valid economic grounds pursuant to Article 89.2 of the LIS. If this regime is applied, the Transfer Tax on Urban Land (IIVTNU) shall not accrue for the transfer of urban land, and the transaction shall not be subject to Transfer Tax (ITP) or Stamp Duty (AJD) as it constitutes a restructuring.
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