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A query was raised regarding whether a total demerger of two companies can qualify for the special tax neutrality regime. The DGT ruled that this is possible provided that the allocation of shares to shareholders is proportional and the transaction is driven by valid economic reasons rather than solely for tax advantages.
Question posed: Whether it is possible to apply the tax regime established in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax, to the described operations.
For a total spin-off to qualify for the special regime under the LIS, it must comply with the proportional allocation of shares representing the social capital to the partners. Furthermore, the operation must not have fraud or tax evasion as its primary objective, and must be carried out for valid economic reasons such as the restructuring or rationalization of activities. Reasons such as ensuring the survival of a family business or facilitating generational succession may be considered valid.
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