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A single-member company has requested a ruling on whether a total demerger operation can qualify for the special Corporate Tax regime and if valid economic reasons exist. The DGT indicates that, provided the requirements of the Corporate Tax Act and commercial regulations are met, such a regime could apply, provided it is not for the purpose of fraud or evasion.
Question raised 1. Whether the described operation can qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax and whether valid economic reasons exist.
For a total spin-off to qualify for the special regime under the LIS, it must comply with the requirements of tax and commercial regulations. As there is a single shareholder, it is not necessary for the assets to constitute business lines to maintain proportionality. The alleged economic reasons could be valid, although their classification depends on the facts. Regarding VAT, non-applicability requires that the transferred elements constitute an autonomous economic unit.
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