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A query was raised regarding whether a total demerger followed by subsequent mergers can apply the special regime under the Corporate Tax Act. The Directorate General for Taxes (DGT) ruled that, provided commercial requirements are met and the primary purpose is not tax evasion, such operations may qualify for this regime.
Question raised 1º) Whether the described operations of total spin-off and merger could qualify for the tax regime provided in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
A total spin-off may qualify for the special regime if carried out within a commercial scope pursuant to Law 3/2009 and complies with Article 76.2.1ºa) of the LIS. Mergers may apply the regime if they comply with the provisions of Article 76.1 of the LIS and commercial regulations. The mentioned economic motives for family reorganization are considered valid to avoid the application of Article 89.2 of the LIS. In the event that the special regime is applied, the partners shall not include income in their Personal Income Tax (IRPF) and shall maintain the tax values of their holdings.
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