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A livestock company has enquired whether its spin-off operation can qualify for the special tax regime under Corporate Income Tax. The DGT has ruled that this is possible provided commercial requirements are met and the primary purpose of the operation is not tax evasion or tax advantage.
Question posed: Whether the aforementioned operation may qualify for the special tax regime of Chapter VIII of Title VII of the Recast Text of the Corporate Income Tax Law, approved by Royal Legislative Decree 4/2004, of March 5.
To apply the special spin-off regime, the operation must be carried out within the commercial sphere in accordance with Law 3/2009. If the allocation of values to the partners is proportional to their previous participation, it is not necessary for the assets to constitute branches of activity. Furthermore, the operation must respond to valid economic motives, such as the reorganization or rationalization of activities, and must not have the primary objective of obtaining a tax advantage.
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