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A query is made as to whether a total spin-off operation of a company may apply the special regime of Corporate Income Tax. The DGT indicates that, if the requirements of the LIS are met and the allocation of values to the partners is proportional, it could be applied provided that its primary purpose is not tax advantage.
Question raised
To apply the special regime for total spin-offs, the operation must comply with the requirements of Article 76.2.1º a) of the LIS, including the proportional allocation of values to the partners. It is not necessary for the assets to constitute business lines if the allocation is proportional. However, pursuant to Article 89.2 of the LIS, the regime shall not apply if the operation has the primary objective of tax fraud or evasion, or if it lacks valid economic reasons.
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