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V0897-15 ·23 March 2015 ·consulta-vinculante Medium impact
Tax

Special regime for total demergers may apply if LIS requirements are met and valid economic reasons exist

An entity has enquired whether its demerger operation can qualify for the special tax regime for corporate reorganisations. The DGT has ruled that this is possible provided the operation meets the commercial definition of a total demerger and is carried out for valid economic reasons rather than purely for tax purposes.

In 6 key points

How it affects those involved

Companies planning demergers must ensure the transaction is driven by genuine economic motives and complies with the Corporate Income Tax Law (LIS) to benefit from the special tax regime.

Lifecycle

2015-03-23PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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