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22. Taxmatters
a) Consolidated tax group
Pursuant to current legislation, the consolidated tax group includes Atresmedia Corporación de
Medios de Comunicación, S.A., as the Parent, and the Spanish subsidiaries that meet the
requirements provided for in Spanish legislation regulating the taxation of the consolidated
profits of corporate groups (inwhich an ownership interest of more than 75% is held).
The Group's other subsidiaries file individual tax returns in accordance with the tax legislation
in force in each country.
Pursuant to Spanish Corporation Tax Law 43/1995, of 27 December, on 26 December 2000,
Atresmedia Corporación de Medios de Comunicación, S.A. notified the Madrid tax authorities of
its decision to file consolidated income tax returns. Application of the consolidated tax regime
shall be considered indefinite provided that the requirements established in the current Article
67 of the Consolidated Spanish Corporation Tax Law are met and the Group does not opt to
cease to apply the regime. The filing of consolidated tax returns gives rise to reciprocal intra-
Group balances, due to the offset of the losses incurred by certain companies against the
profit earned by other Group companies.
On 16 December 2011, the joint merger agreement entered into on 30 June 2011 was
executed in a public deed; under this agreement, Publicidad 3, S.A.U. absorbed Antena de
Radiodifusión, S.A.U., Medipress Valencia, S.A.U., Canal Radio Baleares, S.L.U., Radio Media
Aragón, S.L.U., Canal Radio Madrid, S.L.U., Canal Radio Valencia, S.L.U. and Uniprex, S.A.U.,
which simultaneously and in the same act absorbed Radio Noticias Noventa, S.A.U., Radio
Sistemas Radiofónicos Cinco, S.L.U. and Rkor Radio, S.L.U. in a preliminary phase.
The resolution to change the resulting company's name to Uniprex, S.A.U. is contained in the
aforementioned deed.
Consequently, the new company Uniprex, S.A.U. acquired the assets and liabilities of the
absorbed companies, which were dissolved without liquidation, in accordance with their
balance sheets, whose assets and liabilities were transferred en bloc to the absorbing
company.
The merger goodwill, which at 16 December 2011 amounted to EUR 99,137 thousand for tax
purposes (comprising EUR 5,599 thousand of Rkor Radio, EUR 1,360 thousand of Medipress
Valencia, EUR 8,591 thousand of Antena de Radiodifusión and EUR 83,587 thousand of
Uniprex) may be amortised at an annual rate of 1% in 2012 and 2013, as defined in Article
26.1.3. of Royal Decree-Law 20/2012, of 13 July, introducing measures to ensure budgetary
stability and foster competitiveness, and at a rate of 5% from 2014 onwards, regardless of its
recognition for accounting purposes. This amortisation is deductible for tax purposes. The
merger goodwill for tax purposes does not coincide with that recognised for accounting
purposes (see Note 5).
On 5 June 2009, the public deed was executed of the agreement for themerger by absorption
of Radio Tormes, S.A. (Sole-Shareholder Company), Radio Alamedilla, S.A. (Sole-Shareholder
Company), Compañía Tres Mil Ochocientos, S.L. (Sole-Shareholder Company), La Veu de
LLeida, S.L. (Sole-Shareholder Company), Grupo Universal de Emisoras Radio Amanecer, S.A.
(Sole-Shareholder Company), Ondadit, S.L. (Sole-Shareholder Company) and Unión Ibérica de
Radio, S.A. (Sole-Shareholder Company) into the sole shareholder Uniprex, S.A. (Sole-
Shareholder Company) through the dissolution without liquidation of the absorbed companies
