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The inquiry asks whether a total spin-off operation may qualify for the special tax regime of the TRLIS. The DGT indicates that if the operation meets commercial requirements and is carried out for valid economic reasons without seeking a tax advantage, said regime may be applied.
Question posed: Whether the described operation may qualify for the special tax regime of Chapter VIII, Title VII of the Recast Text of the Corporate Income Tax Law approved by Royal Legislative Decree 4/2004, of March 5.
To apply the special total spin-off regime, the operation must be carried out within the commercial sphere pursuant to Law 3/2009. If the partners receive shares in the beneficiary entities in proportion to their previous holding, it is not necessary for the assets to constitute branches of activity. Furthermore, the operation must respond to valid economic reasons and not have fraud or tax evasion as its principal objective.
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