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A company has requested a ruling on whether its proposed demerger project (both partial and total) qualifies for the special Corporate Tax regime. The Directorate General of Taxes (DGT) has determined that a partial demerger does not meet the requirements due to a lack of distinct business lines, whereas a total demerger could qualify provided it is justified by valid economic reasons.
Cuestión planteada Si la operación descrita puede acogerse al régimen fiscal especial previsto en el Capítulo VII del título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades.
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