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A medical services parent company in the Canary Islands has enquired whether it can apply the special merger regime when absorbing its wholly-owned subsidiary. The Directorate General for Taxes (DGT) has ruled that the transaction may qualify for this regime, provided it meets all legal requirements and its primary objective is not tax fraud or evasion.
Question posed: Whether the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax is applicable.
The merger operation may qualify for the tax neutrality regime under Chapter VII of Title VII of the LIS if it complies with article 76.1 c) and is carried out for valid economic reasons. The existence of tax loss carryforwards or tax credits does not invalidate the regime, provided that the merger benefits the resulting activities and is not primarily intended to exploit said credits. The regime shall not apply if the primary objective is tax fraud or evasion.
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