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A leasing and investment company inquires whether its partial or total spin-off may apply the special Corporate Income Tax regime and whether its economic motives are valid. The DGT determines that a total spin-off is possible, but a partial spin-off is not if autonomous lines of business are not segregated.
Question posed: Whether the proposed operations could qualify for the special tax regime regulated in Chapter VII of Title VII of the Corporate Income Tax Law, and whether the economic motives can be considered valid for the purposes of applying the aforementioned special regime.
A partial spin-off only allows for the special regime if the segregated assets constitute an autonomous economic unit and another line of business is maintained in the transferring company. In a proportional total spin-off, it is not necessary for the segregated assets to be lines of business. Motives of succession planning and differentiated management are considered economically valid. For VAT purposes, the transaction shall not be subject to tax if an autonomous economic unit is transferred rather than a mere transfer of assets.
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