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The taxpayer asks whether a total spin-off of its company may qualify for the special tax regime. The DGT responds that, if the operation complies with commercial regulations and is carried out for valid economic reasons and not solely to obtain a tax advantage, said regime may be applied.
Question raised 1) Whether the described operation may qualify for the special tax regime of Chapter VII of Title VII of the Corporate Tax Law 27/2014, of November 27.
For a total spin-off to qualify for the special regime, it must be carried out commercially in accordance with Law 3/2009. If the shareholders receive shares in proportion to their previous holding, it is not necessary for the assets to constitute business lines. The operation must not have fraud or tax evasion as its primary objective, and must be based on valid economic reasons such as the rationalization of activities. In the event of a total spin-off, the negative tax bases of the extinguished entity may be offset by the acquiring entities according to the rules of Article 84.2.
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