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A real estate leasing company has enquired whether its proposed total demerger project can qualify for the special tax regime. The DGT has ruled that, provided the transaction meets commercial requirements and the allocation of shares is proportional, it may apply as long as its primary purpose is not to obtain a tax advantage.
Question posed: Whether the described transaction could qualify for the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
If the spin-off is carried out under Article 69 of Law 3/2009 and the allocation of values to the partners is proportional to their shareholding, the requirements of Article 76.2.1a) of the LIS are met. However, to apply the special regime, the transaction must respond to valid economic reasons and must not have the primary objective of tax fraud or evasion. Reasons of restructuring, organizational simplification, or management improvement may be considered valid pursuant to Article 89.2 of the LIS.
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