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The DGT states that if the operation meets commercial and proportionality requirements in the allocation of shares, the special fiscal neutrality regime may apply, provided it is not used for tax fraud or evasion.
Question posed: Whether the operation of total spin-off into two new entities, one dedicated to industrial activity, including all elements inherent to industrial activity, and another to financial and investment activities, with current financial assets and cash surpluses, assigning the shares of both beneficiary entities to the shareholders of the spun-off company in the same proportion as they currently hold in it, can be considered to be carried out for valid economic reasons due to business restructuring, so as to allow the application of the special tax regime provided for in Chapter VII of Title VII of Law 27/2014.
Si la escisión se realiza en el ámbito mercantil y los socios reciben participaciones en las nuevas entidades de forma proporcional a su participación previa, se cumplen los requisitos del artículo 76.2.1º a) de la LIS. En este caso, no es necesario que los patrimonios constituyan ramas de actividad. La aplicación del régimen de neutralidad fiscal queda condicionada a que el objetivo principal no sea el fraude o la evasión fiscal, según el artículo 89.2 de la LIS.
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