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A company with three distinct activities intends to carry out a non-proportional total spin-off to separate its businesses. The DGT rules that to apply the special tax regime, the transferred assets must constitute autonomous business lines and the transaction must be supported by valid economic reasons.
Question posed: Whether the application of the special regime under Chapter VIII of Title VII of the consolidated text of the Corporate Income Tax Law is appropriate for the proposed operation, and whether the alleged motives are considered economically valid for these purposes.
For a non-proportional total spin-off to qualify for the special regime, the spun-off assets must constitute business lines within the originating entity, understood as autonomous economic units capable of operating by their own means. Furthermore, the operation must not have fraud or tax evasion as its primary objective, but rather valid economic motives such as the restructuring or rationalization of activities. In the event of subrogation, the beneficiary entities shall assume the tax benefit requirements of the transferor, such as the investment reserve in the Canary Islands.
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