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The DGT states that if the operation meets commercial and proportional requirements, fiscal neutrality may apply as long as the main objective is not tax fraud or evasion.
Question posed: Whether the described restructuring operation of proportional total spin-off followed by a legacy of third-party property would be entitled to apply the tax neutrality regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
Si la escisión se realiza en el ámbito mercantil cumpliendo los requisitos de la LIS y los socios reciben participaciones de forma proporcional, se puede aplicar el régimen de neutralidad fiscal. Esto implica que no se integrarán plusvalías en la entidad transmitente ni en las adquirentes, y los socios residentes en España no integrarán rentas por la atribución de valores. No obstante, el régimen no será aplicable si el objetivo principal de la operación es el fraude o la evasión fiscal.
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