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A company has requested a ruling regarding a total spin-off intended to create two new entities, where each shareholder would receive 100% of one of them. The Directorate General for Taxes (DGT) ruled that, as this is a non-proportional spin-off, the assets must constitute business lines, which is not the case with shares in companies.
Cuestión planteada Si resulta aplicable a la operación descrita el régimen de neutralidad fiscal regulado en el Capítulo VII del Título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades, así como si existen motivos económicos válidos a efectos del artículo 89.2 de la LIS.
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