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A family asks whether the total split of three companies to create four new ones can benefit from the special tax neutrality regime and how it affects negative taxable bases. The DGT responds that the special regime applies if proportionality and economic reasons are met.
Question posed: Is the Special Regime for mergers, demergers, asset contributions, and exchange of securities regulated in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax applicable to the described operations?
The described operation may qualify for the tax neutrality regime if carried out under the requirements for total demerger set forth in Article 76.2.1º a) of the LIS. As it is a proportional demerger, it is not necessary for the assets to constitute business lines. The beneficiary companies shall subrogate into the negative tax bases subject to the limits of Articles 84.2 and DT 16th of the LIS. The existence of negative tax bases does not invalidate the regime if the predominant purpose of the operation is not their exploitation or if it is part of a liquidation plan.
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