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A consulting company proposes a merger (absorption or reverse merger) to simplify its structure and reduce costs. The DGT determines that the operation may qualify for tax neutrality if carried out for economic reasons and not with the primary objective of fraud or evasion.
Question raised 1. Whether the reasons adduced are considered economically relevant for the purposes of applying the special deferral regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
The merger operation may qualify for the tax neutrality regime if it meets the requirements of Articles 76.1 a) or c) of the LIS and is carried out under the commercial framework of Royal Decree-Law 5/2023. The existence of negative tax bases does not invalidate the regime, provided that the merger strengthens the activity and is not primarily intended to exploit the bases. The absence of valid economic reasons may presume fraud, but the mere pursuit of a legitimate tax advantage is part of the economy of choice.
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