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A consultancy entity proposes a full split of its assets to optimise its structure and management. The DGT responds that, if carried out in the commercial sphere, it could qualify for the tax neutrality regime of the Corporate Income Tax.
Question raised 1º) Whether the described operation could qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
If the spin-off is carried out in accordance with Royal Decree-Law 5/2023, it meets the requirements of Article 76.2.1º a) of the LIS. As it is a proportional distribution of assets to the shareholders, it is not necessary for the assets to constitute business lines for the purpose of neutrality. The application of this regime implies that no capital gains will be recognized in the transferring company or the shareholders, and the values and holding period of the assets will be maintained in the acquiring companies. However, the regime shall not apply if the primary objective is tax fraud or evasion.
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