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A consultancy company proposes a commercially improper partial financial spin-off to transfer shares in a subsidiary to its parent company. The DGT states that the transaction could apply the special regime of fiscal neutrality provided it is commercially classified as a spin-off and meets both commercial and fiscal requirements.
Question posed: Whether the described operation could qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
In order for a financial partial spin-off to qualify for the special regime, it must comply with the requirements of commercial law, segregating majority holdings and maintaining another line of business or majority holdings in the spun-off entity. The line of business must have a differentiated organization of material and human resources prior to the operation. Finally, the primary objective of the operation must not be tax fraud or tax evasion.
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