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A company inquires whether its restructuring project may qualify for the special spin-off regime and whether its reasons are valid. The DGT responds that, if the spin-off is total and proportional, it meets the requirements and the stated reasons are valid economic reasons.
Question posed: Whether the proposed restructuring operation could qualify for the special tax regime regulated in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax. And whether the economic reasons can be considered valid for the purposes of applying the aforementioned special regime.
For an operation to be considered a total spin-off under the LIS, it must be carried out in a commercial context in accordance with Law 3/2009. If the spin-off is total and the attribution of values to the partners is proportional, it is not necessary for the segregated assets to constitute business lines. Likewise, the stated reasons of restructuring, management optimization, asset protection, and generational succession are considered valid economic reasons to avoid the application of Article 89.2 of the LIS.
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