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A group of partners has queried whether a merger by absorption followed by a non-proportional total demerger can qualify for the special Corporate Tax regime. The Directorate General for Taxes (DGT) indicates this is possible provided the segregated assets constitute business lines and valid economic reasons exist.
Cuestión planteada Si la operación descrita puede acogerse al régimen fiscal previsto en el Capítulo VII del Título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades y si existen motivos económicos válidos.
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