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An entity inquires whether its total spin-off operation may qualify for the special tax regime of the Corporate Income Tax. The DGT responds that, if the spin-off meets commercial requirements and aims for valid economic reasons rather than tax advantage, said regime is applicable.
Question posed: Whether the described operation may qualify for the special tax regime of Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
To apply the special total 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 business lines. Furthermore, the operation must not have fraud or tax evasion as its primary objective, and must be based on valid economic reasons such as the restructuring or rationalization of activities.
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