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A family group asks whether a merger operation can apply for the special corporate tax regime. The DGT responds that if the operation meets commercial requirements and has valid economic reasons, it may qualify for the regime and its tax benefits.
Question raised 1) Whether the described transaction can benefit from the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
If the transaction is carried out pursuant to Law 3/2009 and complies with Article 76.1 of the LIS, it could benefit from the special merger regime. Partners resident in Spain would not include in their tax base the income from the attribution of values, which shall be valued at their tax value. The regime shall not apply if the primary objective is tax fraud or evasion, or if it lacks valid economic reasons. The reasons of organizational simplification and resource optimization presented could be considered valid.
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