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The applicant asks whether a demerger of their assets can qualify for the special Corporate Tax regime and if valid economic reasons must exist. The DGT indicates that, provided commercial regulations are met, the special regime may apply as long as its primary purpose is not tax evasion or tax advantage.
Cuestión planteada Si la operación descrita podría acogerse al régimen fiscal previsto en el Capítulo VII del Título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades y si existen motivos económicos válidos.
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