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The taxpayer asks whether a total spin-off operation may qualify for the special tax regime of the TRLIS. The DGT responds that, if the spin-off is carried out under the Structural Changes Law and has legitimate economic purposes, it meets the requirements for said regime.
Question posed: Whether the described operation may qualify for the special tax regime of Chapter VIII of Title VII of the recast text of the Corporate Income Tax Law, approved by Royal Legislative Decree 4/2004, of March 5.
To apply the special spin-off regime, the operation must be carried out within the commercial sphere pursuant to Law 3/2009. If the allocation of values to the partners is proportional to their previous participation, it is not necessary for the assets to constitute branches of activity. Furthermore, the operation must not have the primary objective of tax fraud or evasion, and must respond to valid economic reasons such as the restructuring or rationalization of activities.
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