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The taxpayer asks whether a non-proportional total spin-off may apply the special tax regime of the Corporate Income Tax. The DGT indicates that, being non-proportional, it is an essential requirement that the spun-off assets constitute business lines within the originating entity.
Question posed: Whether the proposed spin-off operation may qualify for the special tax regime regulated in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
In a non-proportional total spin-off, each of the spun-off assets must constitute a business line within the entity undergoing the spin-off. A business line is a set of assets that form an autonomous economic unit capable of operating by its own means. This requires an organization of distinct material and human resources for each activity within the spun-off entity prior to the operation. Furthermore, the operation must be carried out for valid economic reasons and not with the primary objective of tax fraud or evasion.
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