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The DGT confirms that the transfer of a subsidiary's shares to shareholders does not constitute a partial financial split, as there is no beneficiary entity or exchange. The transaction must be treated as a distribution of reserves or as a dividend in kind.
Question raised: Tax implications regarding Corporate Income Tax, Transfer Tax and Stamp Duty, and Personal Income Tax for shareholders receiving shares of the spun-off company.
The transfer of shares in a subsidiary to shareholders, without exchange or capital reduction, is classified under Personal Income Tax (IRPF) as income from movable capital due to the distribution of reserves or a dividend in kind. If implemented through a capital reduction with the return of contributions, the treatment will depend on whether the return originates from undistributed profits or from contributions. Under the Non-Resident Income Tax (ITPAJD), as it is not a restructuring operation, it must be taxed under the modality of corporate operations.
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