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The applicant inquired whether their total merger and demerger operations could qualify for the special regime under Corporate Income Tax. The DGT ruled that this is possible provided they meet the requirements of commercial regulations and the TRLIS, and are supported by valid economic reasons.
Question posed In relation to the proposed merger and total spin-off operations, whether they may qualify for the regime provided for in Chapter VIII of Title VII of the TRLIS.
For a merger or total spin-off to qualify for the special regime of the TRLIS, it must be carried out within the commercial sphere pursuant to Law 3/2009 and comply with the requirements of Article 83 of the TRLIS. In the case of a proportional total spin-off, it is not necessary for the segregated assets to constitute business lines. Furthermore, the operation must not have fraud or tax evasion as its primary objective, and must respond to valid economic motives such as the restructuring or rationalization of activities.
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