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The DGT determines that these transactions produce the same effect as a non-activity branch split, thus the neutrality regime does not apply.
Question posed: Possibility of applying the tax neutrality regime to the previously described operations under Corporate Income Tax.
La aplicación del régimen de neutralidad fiscal en operaciones de reestructuración requiere que los bienes transmitidos constituyan una rama de actividad o una cartera de control. Si la concatenación de operaciones (canje, aportación y escisión) produce los mismos efectos prácticos que una escisión parcial de activos que no son rama de actividad, no podrá aplicarse el régimen especial. El objetivo de la operación no debe ser la mera obtención de una ventaja fiscal sin motivos económicos válidos.
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