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A query was raised regarding whether a total demerger of a leasing company could qualify for the special Corporate Income Tax regime and what constitutes valid economic reasons. The DGT indicates that the regime may apply if legal requirements are met, but warns that if the operation is combined with a sale of shares to circumvent proportionality rules, the special regime will not be applicable.
Question posed: Whether the described total demerger can qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax and whether valid economic reasons exist.
The transaction may qualify for the special regime if it meets the requirements for total demerger under Article 76.2.1ºa) of the LIS and is carried out for valid economic reasons. If the shareholders receive shares on a proportional basis, it is not necessary for the assets to constitute business lines. However, if the demerger is combined with a subsequent exchange or sale of shares to break the proportionality, the special regime will not apply as it would not constitute a restructuring, but rather a transaction to facilitate the separation of shareholders.
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