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A consultancy firm proposes a reorganisation involving a full spin-off, a share exchange to establish a holding company, and the contribution of a leasing activity. The DGT examines whether these operations meet the requirements for applying the special tax regime for corporate reorganisation.
Question raised 1) Whether the described operation may qualify for the special tax regime under Chapter VII of Title VII of Corporate Income Tax Law 27/2014, of November 27.
A total demerger may qualify for the special regime if it is carried out within a commercial framework and the shareholders receive proportional shares. The exchange of securities is applicable if the new company obtains the majority of voting rights and the requirements of Article 80 of the Corporate Income Tax Law are met. The contribution of real estate from a leasing activity may qualify for the special regime if the assets are used for the economic activity and the period of use is fulfilled. The demerger of an industrial activity is not subject to VAT as it constitutes an economic unit, whereas the demerger of real estate leasing is subject to VAT as it constitutes a mere transfer of assets.
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