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A start-up has requested a ruling on whether its share exchange and total demerger operation can qualify for the special tax regime. The Directorate General for Taxes (DGT) has responded that this is possible, provided that all legal requirements are met and the primary purpose of the transaction is not to obtain a tax advantage.
Question raised Whether the described operations could 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.
Para el canje de valores, la entidad beneficiaria debe obtener la mayoría de derechos de voto y cumplir los requisitos del artículo 80 de la LIS, excluyendo a socios en paraísos fiscales. En la escisión total, si no se altera la proporcionalidad de los socios, no es necesario que los patrimonios sean ramas de actividad. En ambos casos, la operación debe responder a motivos económicos válidos y no a la mera búsqueda de una ventaja fiscal según el artículo 89.2 de la LIS.
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