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A holding company enquires whether its partial demergers, financial demergers, and improper mergers meet the requirements of the special Corporate Tax regime and possess a valid economic reason. The DGT indicates that, provided the commercial and tax requirements regarding business lines or control portfolios are met and valid economic reasons are proven, the transactions may qualify for the regime.
Cuestión planteada Si cumplen en las tres operaciones descritas los requisitos para la aplicación del régimen fiscal especial del capítulo VII del título VII de la Ley del Impuesto sobre Sociedades, y si en relación con las mencionadas operaciones los objetivos que se persiguen responden a un motivo económico valido a efectos de dicho régimen.
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