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A company proposes a merger by absorption followed by a non-proportional total spin-off into two new entities. The Directorate-General for Tax (DGT) has ruled that the spin-off does not meet the requirements for the special Corporate Tax regime, as the existence of distinct business lines was not proven, although the transactions will not be subject to VAT.
Question raised 1. Whether the described operations may qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax and whether valid economic reasons exist.
Para que una escisión total no proporcional se acoja al régimen especial de IS, los patrimonios segregados deben constituir ramas de actividad, entendidas como unidades económicas autónomas capaces de funcionar por sus propios medios. En este caso, no se aprecia una gestión y organización diferenciada previa en la sociedad escindida que permita identificar tales ramas de actividad. Respecto al IVA, las transmisiones no estarán sujetas al impuesto al acompañarse de la estructura organizativa necesaria para ser unidades económicas autónomas.
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