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A real estate development and rental management company inquires whether its total demerger may qualify for the special tax regime. The DGT responds that it is possible if the transaction complies with commercial regulations and is based on valid economic reasons.
Question posed: Whether the described transaction may qualify for the special tax regime under Chapter VII of Title VII of Corporate Income Tax Law 27/2014, of November 27, and whether there would be any temporal limitation if the company dedicated to residential leasing were to undertake a real estate sales or development business in the future.
If the transaction is carried out under Article 69 of Law 3/2009, it complies with the definition of total demerger in Article 76.2.1a) of the LIS. Since shares are allocated to the partners proportionally, it is not necessary for the assets to constitute business lines. The special regime is applicable provided that the primary objective of the transaction is not tax fraud or evasion and that it is based on valid economic reasons, such as improved management.
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