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A company engaged in real estate leasing has enquired whether its total demerger operation can benefit from the special tax regime. The DGT indicates that this may apply if the requirements of the Corporate Income Tax Act (LIS) and commercial principles are met, provided that the primary purpose is not to obtain a tax advantage.
Question posed: Whether the described operation could qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
The operation could qualify for the special regime for total demergers if it complies with tax and commercial regulations. Since the partners receive shares on a proportional basis, it is not necessary for the assets to constitute business lines. However, the application of the regime requires that the operation's primary objective is not tax fraud or evasion, and it must be based on valid economic reasons rather than the mere pursuit of a tax advantage.
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