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An entity has requested clarification on whether the special regime for business reorganisations can be applied to a series of exchange and spin-off operations. The DGT has determined that the exchange and the first proportional spin-off meet the requirements; however, the second spin-off is not permissible because the shares in other companies do not constitute a business line.
Question posed: Whether the application of the special regime of Chapter VIII of Title VII of the consolidated text of the Corporate Income Tax Law is appropriate for the proposed operations, and whether the alleged motives are considered economically valid for these purposes.
The exchange of securities and the proportional total spin-off may qualify for the special regime if the residency and proportionality requirements of the TRLIS are met. However, a non-proportional total spin-off requires that the segregated assets constitute business lines. Holdings in other entities are not considered a business line, as the management of holdings is not an autonomous economic activity. Family reorganization motives are considered economically valid.
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