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A company has proposed a partial financial spin-off to segregate a majority stake in a subsidiary. The DGT is analysing whether this operation can qualify for the special tax neutrality regime and whether the economic motives are valid.
Question posed: Whether the application of the special regime of Chapter VIII of Title VII of the Recast Text of the Corporate Income Tax Law is appropriate for the proposed financial spin-off operation, and whether the alleged reasons are considered economically valid for these purposes.
Partial financial spin-off may qualify for the special regime of the Recast Text of the Corporate Income Tax Law if commercial regulations are met and a line of business or majority holdings in other entities are maintained within the spun-off entity. The reasons for limiting asset liability to protect a subsidiary's activity against the parent company's cash flow difficulties are considered economically valid. The existence of the line of business is a matter of fact that must be proven before the Administration. Regarding the ITPAJD, the operation shall be not subject to or exempt from tax if it is considered a restructuring.
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