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The applicant asks whether a total demerger intended to separate agricultural and leasing activities can benefit from the special Corporate Tax regime. The DGT rules that, provided commercial regulations are met and shareholders receive proportional shares, the regime may apply as long as the primary purpose is not tax avoidance or undue tax advantage.
Question posed: Whether the described total spin-off operation could qualify for the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
For a total spin-off to qualify for the special regime under Article 76.2 of the LIS, it must comply with the commercial definition of a total spin-off. If the shareholders receive shares in the beneficiary entities in proportion to their previous holding, it is not necessary for the assets to constitute business lines. Furthermore, the transaction must be carried out for valid economic reasons and not merely for the purpose of obtaining a tax advantage.
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