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A query was raised regarding whether a total demerger of a company with a single shareholder could qualify for the special merger and demerger regime. The Directorate General for Taxes (DGT) indicates that, provided commercial regulations are met and the primary purpose is not fraud or tax advantage, such a regime could apply.
Question posed: Whether the described operation may benefit from the tax regime established in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
If the operation is carried out under the commercial concept of total spin-off pursuant to Article 69 of Law 3/2009, it fulfills the requirements of Article 76.2.1.a) of the LIS. As there is a single shareholder, it is not necessary for the assets to constitute business lines. However, to apply the special regime, the operation must not have the objective of tax fraud or evasion, and must be based on valid economic reasons according to Article 89.2 of the LIS.
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