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An entity inquires whether its total spin-off project may qualify for the special regime under the Corporate Income Tax Law and whether its motives are valid. The DGT responds that, as it is a proportional spin-off, it meets the requirements and that specialization by sectors constitutes a valid economic motive.
Question posed: Whether the proposed operation could qualify for the special tax regime regulated in Chapter VII of Title VII of the Corporate Income Tax Law, and whether the economic motives can be considered valid for the purposes of applying the aforementioned special regime.
The operation may apply the special spin-off regime if it is carried out under commercial regulations and is a proportional total spin-off, without the requirement that the assets constitute business lines. To avoid the application of Article 89.2 of the LIS, the operation must not have the objective of tax fraud or evasion. The separation of sectors by specialization and risk levels is considered a valid economic motive.
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