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A hotel company intends to carry out a partial financial spin-off, transferring 31.29% of its shares to its sole shareholder. The DGT states that since the transferred shareholding is not a majority of the capital, the conditions of article 76.2.1(c) of the LIS are not met.
Question raised 1. Whether the described operation meets the requirements to qualify for the special tax regime provided for in Chapter VII of Title VII of the LIS, by way of financial spin-off (Article 76.2.1.c of the LIS).
Para acogerse a la neutralidad fiscal en una escisión parcial financiera, la participación segregada debe conferir la mayoría del capital social en las entidades beneficiarias. En este caso, al transmitirse solo un 31,29% de la sociedad C, no se cumple el requisito de mayoría exigido por el artículo 76.2.1º c) de la LIS. Por tanto, la operación no puede ampararse en el régimen especial de neutralidad fiscal.
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