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The taxpayer asks whether the segregation of majority shareholdings in other entities may qualify for the special spin-off regime. The DGT responds that it is possible if the spun-off entity maintains a line of business with differentiated material and human resources.
Question raised 1. Whether the special regime of Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax, is applicable to the proposed business restructuring operation.
For a financial spin-off to qualify for the special regime, the segregated assets must consist of majority shareholdings and the spun-off entity must maintain a line of business or majority shareholdings in other entities. The line of business requires a differentiated business organization with material and human resources prior to the operation. Furthermore, the primary objective of the operation must not be the obtaining of a tax advantage without valid economic reasons.
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