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The DGT states that if the split meets commercial and proportionality requirements, the regime may apply, provided the main objective is not fiscal advantage.
Question posed: Whether a valid economic reason exists for the spin-off operation to qualify for the special regime relating to mergers, spin-offs, contributions of assets, exchange of securities, and change of registered office of a European Company or a European Cooperative Society from one Member State to another of the European Union, as regulated in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
Si la escisión se realiza bajo el Real Decreto-ley 5/2023 y mantiene la proporcionalidad de la participación del socio único, cumple los requisitos del artículo 76.2.1º a) de la LIS. En este caso, no se integrarán rentas en la entidad transmitente ni en los socios, y los bienes mantendrán su valor y antigüedad fiscal. No obstante, el régimen no se aplicará si el objetivo principal de la operación es el fraude o la obtención de una ventaja fiscal sin motivos económicos válidos.
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