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The taxpayer asks whether a merger followed by a partial demerger of its activities can qualify for the special Corporate Tax regime. The DGT rules that this is possible provided that commercial requirements are met, business lines are transferred, and the primary purpose of the operation is not tax evasion or tax advantage.
Question raised: It is asked whether the described merger and partial demerger operations could qualify for the special tax regime regulated in Chapter VIII of Title VII of the TRLIS.
For a merger or partial demerger to qualify for the special regime, it must be carried out within the commercial sphere and comply with the requirements of the TRLIS. In a partial demerger, the segregated elements must constitute branches of activity (autonomous economic units), and the allocation of values to shareholders may be non-proportional if the acquired assets are branches of activity. Finally, the operation must not have the primary objective of tax fraud or evasion, requiring valid economic motives such as the restructuring of activities.
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