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A natural person asks whether a corporate reorganisation (merger and creation of a holding company via contributions) can benefit from the special corporate tax regime. The DGT responds that it can, provided the LIS requirements are met and the transaction has valid economic reasons, not just fiscal ones.
Question raised 1) Whether the described operations may qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
The merger may qualify for the special regime under the CIT if it meets the commercial requirements and Art. 76.1.a). The contribution of shares in entity M is applicable to the special regime if the participation and ownership requirements of Art. 87 are met. The exchange of securities may qualify for the regime if the beneficiary entity obtains the majority of voting rights and the requirements of Art. 80 are met. The transfer of a property undergoing renovation is considered a mere transfer of assets subject to VAT, not an autonomous economic unit.
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