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An entity has enquired whether a total demerger of a company, followed by the non-monetary contribution of a plot of land to a new company, can qualify for the special regime under Corporate Income Tax. The Directorate General for Taxes (DGT) responds that this is possible provided that participation requirements are met and the transaction is driven by valid economic reasons rather than being purely for tax purposes.
Question posed: Whether the described transactions may qualify for the special tax regime of Chapter VIII, Title VII of the Recast Text of the Corporate Income Tax Law approved by Royal Legislative Decree 4/2004, of March 5.
For a total spin-off, if the allocation of values to the partners is proportional, it is not necessary for the assets to constitute business lines. In a non-monetary contribution, the regime applies if the receiving entity is a resident in Spain and the contributing entity maintains a share of at least 5% of the equity of the receiving entity, either before or after the transaction. Finally, the transaction must respond to valid economic reasons, such as the restructuring or rationalization of activities, and must not have the primary objective of fraud or tax advantage.
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