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A company asks whether its proposal to split into two new companies meets the conditions for the special tax-neutral regime for mergers and spin-offs. The DGT responds that if the operation is carried out under commercial law and shareholders receive proportional shares, it could qualify for this tax-neutral regime.
Question raised 1. Whether the projected operation meets the requirements for the application of 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.
If the total demerger is carried out within a commercial framework and the partners receive shares in proportion to their previous holding, the requirements of Article 76.2.1º a) of the LIS are met. In this case, the income of the transferring entity and that of the partners shall not be included in the tax base, and the values and seniority of the assets shall be maintained. However, the regime shall not be applicable if the main objective of the operation is tax fraud or evasion (Art. 89.2 LIS).
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