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V0872-21 ·13 April 2021 ·consulta-vinculante Medium impact
Tax

Total demerger may qualify for special tax regime if carried out under the Structural Changes Act

The taxpayer inquired whether a total demerger of their assets could qualify for the special regime under the Corporate Income Tax Act and if their economic motives were valid. The DGT indicated that if the operation complies with Law 3/2009, it could qualify for the regime, provided its primary purpose is not tax evasion or tax advantage.

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2021-04-13PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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