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A query is made as to whether a proportional total demerger followed by a legacy of third-party property is entitled to the special regime for mergers and demergers. The DGT indicates that, if the commercial transaction complies with the CITL and the allocation of values is proportional, it could qualify for the regime, provided that its primary objective is not tax advantage.
Question posed: Whether the described restructuring operation of a proportional total demerger followed by a legacy of third-party property would be entitled to the special regime regulated in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax
If the transaction is carried out in a commercial context in accordance with Royal Decree-Law 5/2023 and complies with Article 76.2.1.a) of the CITL, it could qualify for the special regime. In the event of a proportional allocation of shares to the partners, it is not necessary for the assets to constitute business lines. However, the regime shall not apply if the primary objective of the restructuring is fraud, evasion, or the mere obtaining of a tax advantage without valid economic reasons.
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