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A query was raised regarding whether a total demerger operation can apply the special Corporate Tax regime. The DGT indicates that, provided legal requirements are met and the allocation of values is proportional, it could be applied as long as its primary purpose is not to obtain a tax advantage.
Cuestión planteada
Para que una escisión total se acoja al régimen especial, debe cumplir los requisitos del artículo 76.2.1ºa) de la LIS. Si la atribución de valores a los socios es proporcional a su participación previa, no es necesario que los patrimonios constituyan ramas de actividad. No obstante, según el artículo 89.2 de la LIS, el régimen no se aplicará si la operación tiene como principal objetivo el fraude o la evasión fiscal, o carece de motivos económicos válidos.
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