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A consulting entity proposes a demerger operation to distribute real estate among heirs. The DGT rules that the special Corporate Tax regime cannot be applied because the operation does not constitute a total or partial demerger under the law, as there are no distinct business lines and no proportionality in the allocation.
Question posed 1) Whether the described operation may qualify for the special tax regime under Chapter VIII, Title VII of the Recast Text of the Corporate Income Tax Law approved by Royal Legislative Decree 4/2004, of March 5.
For a non-proportional total spin-off to qualify for the special regime, the spun-off assets must constitute business lines, i.e., autonomous economic units with distinct material and human resource organization within the originating entity. In the case of a partial spin-off, the allocation of shares must be proportional to those held by the partners of the entity undergoing the spin-off. If the operation is a separation of partners, it does not fall within the special regime of the Recast Text of the Corporate Income Tax Law.
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