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A holding company has enquired whether its plan to absorb subsidiaries and subsequently demerge into four new companies can utilise the special Corporate Tax regime. The DGT indicates that, provided commercial and tax requirements are met and valid economic reasons exist, this regime could apply, alongside VAT non-subjectivity and exemptions from Transfer Tax (ITP/AJD).
Question raised 1. Whether the described operation can qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
For CIT, the merger and total spin-off could qualify for the special regime if they meet the requirements of the LIS and commercial regulations, provided that their primary purpose is not fraud or tax advantage without economic justification. Regarding VAT, the transfer shall not be subject to tax if the elements constitute an autonomous economic unit in the transferor. For ITP and AJD, the operation could be exempt as it is considered a corporate restructuring.
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