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The taxpayer asks whether a demerger operation can apply the special regime of Corporation Tax. The DGT indicates that, provided the requirements of the Corporation Tax Act and commercial regulations are met, it could be applied as long as its primary purpose is not fraud or tax advantage.
Question raised 1. Whether the described operations may qualify for the special regime under Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
For a total spin-off to qualify for the special regime under Chapter VII of Title VII of the LIS, it must comply with the requirements of Article 76.2.1.a) and commercial regulations. If the allocation of values to the partners is proportional to their shareholding, it is not necessary for the assets to constitute business lines. However, the regime shall not apply if the main objective of the operation is fraud, evasion, or the mere obtaining of a tax advantage without valid economic reasons.
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