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A consulting company intends to carry out a financial partial demerger of its shareholding in another entity in favour of its holding company. The DGT rules that the operation may qualify for the special regime if it is classified as a commercial demerger, meets the requirements of the TRLIS, and is supported by valid economic reasons.
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 operation presented. And whether the alleged reasons are considered economically valid for these purposes.
To benefit from the special regime for financial partial demerger, the operation must be commercially classified as a demerger and comply with the requirements of Article 83.2.1.c) of the TRLIS. The segregated assets must constitute a majority interest and the demerged entity must maintain majority interests in other entities or a line of business. Furthermore, the operation must not have fraud or tax evasion as its primary objective, and must be based on valid economic reasons.
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