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The inquiry analyzes whether a securities exchange operation and a partial spin-off may apply the special tax regime of the TRLIS. The DGT determines that the exchange is possible if legal requirements are met and it serves economic purposes, but the partial spin-off does not apply if the segregated assets do not constitute an autonomous line of business.
Question posed: Whether the aforementioned operations may qualify for the special tax regime of Chapter VIII of Title VII of the Recast Text of the Corporate Income Tax Law, approved by Royal Legislative Decree 4/2004, of March 5.
The exchange of securities may apply the special regime if the entity acquires the majority of voting rights and the requirements of residence and valid economic purpose are met. For the partial spin-off, the segregated assets must constitute a line of business, understood as an economic unit capable of operating by its own means. It is not necessary to meet the economic activity requirements of the IRPF for the leasing of real estate, but the operation will not apply if the assets do not possess a differentiated organization.
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