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A consulting entity asks whether a full spin-off of its assets into two new companies may apply to the special corporate tax regime and whether succession and management motives are valid. The DGT states that if the operation meets LIS requirements and economic motives are valid, the special regime may apply, although the validity of motives is a factual issue.
Question raised 1. Whether the described transaction could qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax, and whether valid economic reasons exist.
The transaction could qualify for the special Corporate Income Tax regime if carried out as a full commercial spin-off and the shareholders receive shares on a proportional basis. The reasons regarding succession and management could be considered economically valid, although this is a matter of fact. Regarding VAT, non-applicability requires that the transferred elements constitute an autonomous economic unit within the demerged company. For the Real Estate Tax (IIVTNU), the non-accrual depends on the fulfillment of the circumstances set forth in the second additional provision of the Corporate Income Tax Law.
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