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The taxpayer inquired whether a total demerger operation could apply the special Corporate Tax regime and if its underlying motives were valid. The DGT indicates that if the operation complies with commercial regulations and the allocation of values is proportional, it could qualify for the regime, provided its primary purpose is not tax evasion or obtaining an undue tax advantage.
Question posed: Whether the described operation may qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax, and whether the economic reasons are valid.
For a total spin-off to qualify for the special regime under Chapter VII of Title VII of the LIS, it must meet the requirements of Article 76.2.1º a) and be carried out within the commercial sphere pursuant to Law 3/2009. If the allocation of values to the partners is proportional to their participation, it is not necessary for the assets to constitute branches of activity. However, the regime shall not apply if the primary objective of the operation is tax fraud or evasion, or if it lacks valid economic reasons such as the restructuring or rationalization of activities.
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