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The applicant asks whether a concentration of real estate assets into a single entity can qualify for the special merger regime. The DGT indicates that, provided it complies with commercial regulations and Article 76.1.a) of the Corporate Income Tax Act, this regime may apply as long as there are valid economic reasons and it is not intended for fraud or tax evasion.
Question posed: Whether the described operation 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.
Para acogerse al régimen especial, la operación debe realizarse en el ámbito mercantil según la Ley 3/2009 y cumplir el artículo 76.1.a) de la LIS. La existencia de bases imponibles negativas en la absorbente no impide la aplicación del régimen si las entidades son operativas. La operación no debe tener como principal objetivo el fraude o la evasión fiscal, sino motivos económicos válidos como la racionalización de actividades o la reducción de costes.
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