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The applicant asks whether a total spin-off followed by a merger can qualify for the special regime of Corporate Income Tax. The DGT responds that this is possible provided the requirements of the Corporate Income Tax Act and the Structural Changes Act are met, and valid economic reasons exist.
Question raised: Whether the described total demerger and merger operations may benefit from the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
La escisión total puede acogerse al régimen especial si se realiza en el ámbito mercantil según la Ley 3/2009 y los socios reciben participaciones de forma proporcional. La fusión puede aplicar dicho régimen si cumple los requisitos de la LIS y la normativa mercantil. Para ambas, los motivos económicos alegados (reorganización patrimonial y relevo generacional) pueden considerarse válidos bajo el artículo 89.2 de la LIS.
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