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This ruling examines whether a spin-off of shares followed by a subsequent merger can qualify for the special tax regime under the Corporate Income Tax Act. The DGT determines that direct transfers to shareholders do not qualify, but transfers to a new entity that maintains a line of business do.
Question raised 1) Whether the financial spin-off operation of the consulting entity described can qualify for the special tax regime of Chapter VII of Title VII of the Corporate Income Tax Law 27/2014, of November 27.
The spin-off does not qualify for the special regime if the shares are transferred directly to the shareholders. However, a financial spin-off may qualify for the special regime if the shares are transferred to a newly created entity and the spun-off entity retains a line of business in its assets. For the subsequent merger, it is required to comply with the commercial requirements and those of Article 76.1 of the LIS, provided that valid economic reasons exist and not a merely tax-driven purpose.
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