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A consulting company has proposed a reverse merger in which the subsidiary absorbs the parent company to simplify the structure and improve governance. The Directorate General for Taxes (DGT) has ruled that the transaction may qualify for the special tax neutrality regime, provided it meets the requirements of the Corporate Income Tax Act 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 transaction may qualify for the tax neutrality regime if it is carried out in a commercial context and complies with Article 76.1 of the LIS. The existence of tax loss carryforwards in the absorbed company does not invalidate the regime, provided that the merger strengthens the resulting activities and the predominant purpose is not to exploit said tax credits. The regime shall not apply if the primary objective is tax fraud or evasion, pursuant to Article 89.2 of the LIS.
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