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A company inquired whether a merger by absorption followed by a partial demerger of a business line could qualify for the special Corporate Tax regime. The Directorate General for Taxes (DGT) ruled that this is possible provided commercial and tax requirements are met, and the motives are economic rather than purely tax-driven.
Question posed: Whether the proposed restructuring operations could qualify for the special tax regime regulated in Chapter VIII of Title VII of the consolidated text of the Corporate Income Tax Law. And whether the economic reasons can be considered valid for the purposes of applying the aforementioned special regime.
The operation may qualify for the special regime of the TRLIS if it is carried out within the commercial sphere pursuant to Law 3/2009 and complies with Article 83. A partial spin-off requires that the segregated assets constitute an autonomous economic unit and that another branch of activity is maintained in the transferring entity. The economic reasons must be valid to prevent the purpose from being tax advantage. In a partial spin-off, the right to offset negative tax bases remains with the transferring entity and is not transferred to the acquiring entity.
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