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A company has requested clarification on whether a total demerger can qualify for the special tax regime under the TRLIS. The Directorate General of Taxes (DGT) indicates that this is possible provided commercial requirements are met and there are valid economic restructuring motives. However, it warns that the regime will not apply if the true objective is to facilitate the transfer of shares to obtain a tax advantage.
Question posed: Whether the described operation may qualify for the special tax regime of 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, the operation must comply with the requirements of the Law on Structural Modifications and aim for the restructuring or rationalization of activities. If the spin-off's primary objective is to facilitate the disposal of holdings by the partners to obtain a tax advantage, it will not be considered motivated by valid economic reasons. In such a case, the operation may not be covered by the special regime of Article 83 of the TRLIS.
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