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A company resident in Luxembourg inquires whether its proposed total demerger may apply the special regime of the CIT Act and whether its motives are economically valid. The DGT responds that, if the operation is proportional, said regime may be applied and that the stated business separation motives are considered valid.
Question posed: Whether the proposed operation may qualify for the special regime of Chapter VII of Title VII of the Corporate Income Tax Act, and whether the stated motives are considered economically valid for these purposes.
If the demerger is total and the distribution of shares in the beneficiary entities reproduces the structure of the demerged company, it is considered proportional pursuant to Article 76.2.2 of the CIT Act. In this case, it is not necessary for the segregated assets to constitute business lines to apply the special regime. Likewise, the reorganization motives to separate the management and risks of different businesses are considered economically valid under Article 89.2 of the CIT Act.
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