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A query is made as to whether a total spin-off of two entities from a group may qualify for the special regime of the LIS and whether its motives are valid. The DGT responds that, as it is a proportional spin-off, it meets the requirements and the motives for the rationalization of activities are economically valid.
Question posed: Whether the proposed restructuring operation could qualify for the special tax regime regulated in Chapter VII of Title VII of the Corporate Income Tax Law. And whether the economic motives can be considered valid for the purposes of applying the aforementioned special regime.
If the spin-off is carried out within the commercial sphere according to current regulations, it meets the conditions for a total spin-off under Article 76 of the LIS. As it is a proportional total spin-off, it is not necessary for the segregated assets to constitute branches of activity. The motives of rationalization, patrimonial reorganization, and asset protection against business risks are considered valid economic motives according to Article 89.2 of the LIS.
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