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An entity has enquired whether it can apply the special regime for mergers and demergers to an operation involving an absorption followed by a demerger. The Directorate General for Taxes (DGT) indicates that eligibility depends on whether the activities constitute distinct business branches and whether the primary objective is not the attainment of a tax advantage.
Question posed: Whether the application of the special regime under Chapter VIII of Title VII of the consolidated text of the Corporate Income Tax Law is appropriate for the transactions proposed, and whether the alleged reasons are considered economically valid for these purposes.
For a partial spin-off to qualify for the special regime, the segregated assets must constitute a line of business (autonomous economic unit) and the transferring entity must maintain another line of business. In the case of a financial spin-off, the entity must maintain majority holdings or a line of business. The alleged economic reasons must be valid, but if the primary purpose of the transaction is to facilitate a sale of shares with a tax advantage, the special regime may not be applied.
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