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A company inquires whether its proportional total spin-off may qualify for the special tax regime under the LIS. The DGT determines that if the spin-off is carried out for the purpose of facilitating a subsequent donation of shares, the operation is considered merely preparatory and does not meet the requirements for the special regime.
Question posed: Whether the proposed spin-off may qualify for the special tax regime under Chapter VII of Title VII of Law 27/2014, of November 27.
To apply the special spin-off regime, the operation must be carried out for valid economic reasons and not for the purpose of obtaining a tax advantage. If a proportional total spin-off is linked to a subsequent donation of shares, the same effects occur as a non-proportional spin-off without business branches. In that case, the spin-off would be considered preparatory to the donation and could not qualify for the special regime under Chapter VII of Title VII of the LIS.
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