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A company has requested clarification on whether a restructuring involving a business unit contribution, a total demerger, and an improper merger can qualify for the special Corporate Tax regime and if its underlying motives are valid. The Directorate General for Taxes (DGT) has ruled that, provided all legal and commercial requirements are met, these operations may benefit from said regime and the economic motives presented are considered valid.
Cuestión planteada Si las operaciones de reestructuración planteadas podrían acogerse al régimen fiscal especial regulado en el capítulo VII del título VII de la Ley del Impuesto sobre Sociedades. Y si los motivos económicos pueden considerarse como válidos a efectos de la aplicación del citado régimen especial.
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