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A company that leases hotels and operates a photovoltaic plant has enquired whether its total demerger can qualify for the special tax regime. The DGT indicates that if the operation complies with commercial regulations and shareholders receive proportional shares, the regime may apply provided there are valid economic reasons.
Question raised: Whether the special tax regime regulated in Article 76.2.1ºa of Law 27/2014, of November 27, on Corporate Income Tax, would be applicable to the proposed operation.
For a total spin-off to qualify for the special regime under Article 76.2.1ºa) of the LIS, it must comply with the commercial definition of a total spin-off and the shareholders must receive shares in the new entities in proportion to their previous holding. It is not necessary for the assets to constitute business lines if such proportionality is maintained. However, the regime shall not apply if the primary objective is tax fraud or evasion, or if there are no valid economic reasons for the operation.
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