65 / 148
56
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 amounted to EUR 65,172 thousand for tax purposes may be
amortised at an annual rate of 1% in 2014 and 2015, as defined in Article 2.2
nd
.4.2 of Royal
Decree-Law 16/2013, of 29 October, introducing measures in environmental taxaion matters
and adopting tax and financial measures, and the 34
th
DT d) of Law 27/2014 on Corporate
Tax, respectively and twentieths parts from 2016 regardless of it being recorded. This
amortisation is deductible for tax purposes. The merger goodwill for tax purposes does not
coincide with that recognised for accounting purposes (see Note 4).
On 5 June 2009, the public deed was executed of the agreement for the merger 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
and the transfer en bloc of their assets and liabilities to Uniprex, S.A. (Sole-Shareholder
Company), the absorbing company, which acquired them by universal succession and was
subrogated to all the rights and obligations of the absorbed companies, as stipulated in Article
233 of the Spanish Public Limited Liability Companies Law. The date from which the
transactions of the absorbed companies are considered to have been performed for accounting
and tax purposes by the absorbing company was taken to be 1 January 2009.
The merger gave rise to the merger goodwill shown in Note 5, which differs from the merger
goodwill for tax purposes calculated and amortised as provided for in Article 89.3 of the
Consolidated Spanish Corporation Tax Law.