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A company has enquired whether a spin-off operation can qualify for the special tax regime for European Companies. The DGT has ruled that if the spin-off is carried out in accordance with commercial regulations and its primary purpose is not tax evasion or tax advantage, said regime may be applied.
Question posed: Whether the described operation may qualify for the special tax regime under Chapter VIII, Title VII of the Recast Text of the Corporate Income Tax Law approved by Royal Legislative Decree 4/2004, of March 5.
To apply the special spin-off regime for a European Company, the operation must comply with the requirements for total spin-off under Article 69 of Law 3/2009. If the shareholders receive shares in proportion to their previous holding, it is not necessary for the assets to constitute business lines. Furthermore, the operation must respond to valid economic reasons, such as the restructuring or rationalization of activities, and must not have the primary objective of obtaining a tax advantage.
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