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An entity inquires whether its partial financial demerger and exchange of shares operations may qualify for the special tax regime of the Corporate Income Tax Act. The DGT determines that this is possible provided that the majority shareholding requirements are met and the operation does not have the primary purpose of fraud or tax advantage.
Question posed: Whether the described operations may qualify for the special tax regime under Chapter VII of Title VII of Corporate Income Tax Law 27/2014, of November 27.
A partial financial demerger may qualify for the special regime if the segregated assets consist of majority holdings and the demerged entity maintains majority holdings in other entities or a line of business. The exchange of shares requires that the acquiring entity obtains the majority of voting rights and complies with residency and tax valuation requirements. To apply the regime, the operation must respond to valid economic reasons, such as restructuring or rationalization, and must not have the primary objective of tax advantage.
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