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A query is made as to whether a total spin-off of a company with a single shareholder may apply the special Corporate Income Tax regime. The DGT indicates that, as proportionality is not altered, it is not necessary for the assets to constitute business lines, provided that the operation has valid economic reasons.
Question raised
If the total spin-off meets the requirements of Article 76.2.1º a) of the LIS and the proportionality of the shareholder's participation is not altered, it is not required that the assets constitute business lines. However, to apply the special regime, the operation must not have the primary objective of tax fraud or evasion, but must instead respond to valid economic reasons pursuant to Article 89.2 of the LIS.
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