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An engineering and real estate development company has enquired whether its partial demerger can qualify for the special regime under the Corporate Income Tax Act. The DGT has ruled that this is possible provided the segregated assets constitute an autonomous economic unit and the transaction is driven by economic motives rather than purely tax-related ones.
Question raised 1. Whether the proposed operation may qualify for the special regime under Chapter VII of Title VII of the LIS.
To qualify for the special regime for partial demergers, the transferred assets must constitute a line of business (autonomous economic unit) and the transferring entity must maintain another line of business. The operation must be carried out for valid economic reasons, such as the restructuring or rationalization of activities, and not for the purpose of obtaining a tax advantage. If these requirements are met, partners resident in Spain shall not include in their taxable base the income from the attribution of values, which shall be valued at their tax value.
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