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A query was raised regarding the scope of tax relief in restructuring operations. The DGT clarifies that these operations are not subject to the corporate operations category and are exempt from the transfer tax and stamp duty categories.
Question raised: Scope of the relief provided by Article 45.I.B.10 of the Recast Text of the Law on Property Transfers and Documented Legal Acts.
Business restructuring operations, pursuant to Article 76 of the Corporate Income Tax Law, are not subject to the corporate operations modality of the Recast Text of the Law on Property Transfers and Documented Legal Acts. Furthermore, by application of Article 45.I.B.10 of the same text, these operations are exempt from the modalities of onerous property transfers and documented legal acts, including the public deed.
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