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A company has requested a ruling on whether it can apply the special regime for total demergers when splitting its assets into two entities with a non-proportional allocation of shares. The DGT indicates that this requires the transferred assets to constitute business activities and that the transaction must be supported by valid economic reasons.
Question posed: Whether the special regime of Chapter VIII of Title VII of the recast text of the Corporate Income Tax Law is applicable to the proposed operation, and whether the alleged motives are considered economically valid for these purposes.
In a non-proportional total spin-off, it is an essential requirement that the spun-off assets constitute business lines within the originating entity. A business line is a set of assets capable of functioning by its own means as an autonomous economic unit. The existence of these business lines is a matter of fact that must be proven to the Administration. Furthermore, the operation must not have the primary objective of tax fraud or evasion, but rather valid economic motives.
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