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A business group asks whether its restructuring plan (mergers, splits, share exchanges and contributions) can apply to the special corporate tax regime. The DGT responds that it is possible as long as the operations are carried out in a commercial context and meet the requirements of the LIS.
Question posed: 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.
Merger operations may qualify for the special regime if they are carried out within a commercial scope pursuant to Law 3/2009 and comply with Art. 76.1 LIS. Total spin-offs are valid if they comply with Art. 76.2 LIS and the partners receive shares on a proportional basis. The exchange of securities requires obtaining a majority of voting rights and complying with Art. 80 LIS. Non-monetary contributions must comply with Art. 87 LIS, with the contributor maintaining at least 5% of the equity. All operations must have valid economic reasons to avoid falling under the assumption of tax fraud or evasion under Art. 89.2 LIS.
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