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A family business has enquired whether its non-proportional total spin-off can qualify for the special tax regime. The DGT has ruled that this is possible provided that both the transferred assets and those remaining in the company constitute autonomous business lines and are supported by valid economic reasons.
Question posed: Whether the described operation may qualify for the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
For a non-proportional total spin-off to qualify for the special regime, the spun-off assets must constitute business lines, understood as autonomous economic units capable of operating by their own means. This requires a distinct business organization for each asset group. Furthermore, the operation must be carried out for valid economic reasons and not with the primary objective of obtaining a tax advantage.
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