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A company has requested clarification on whether its restructuring operation can qualify for the special regime for mergers and demergers. The DGT has ruled that this is possible provided that commercial law requirements are met and the existence of an activity branch or a control portfolio with valid economic reasons is proven.
Question posed: Whether the proposed restructuring operation is subject to the special tax regime for mergers and spin-offs regulated in Chapter VIII of Title VII of the Corporate Income Tax Law.
Partial financial spin-off may qualify for the special regime if the entity segregates majority holdings in other entities or a line of business. For a line of business to exist, it must consist of a set of assets that constitute an autonomous economic unit capable of operating by its own means. The operation shall not apply the special regime if its primary objective is tax fraud or evasion without valid economic reasons. Restructuring motives intended to avoid adverse commercial effects due to financing problems are considered economically valid.
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