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A company managing real estate for a family group inquires whether its spin-off project can utilize the special regime. The DGT indicates that, if the operation complies with commercial regulations and the allocation of shares is proportional, said regime could be applied, provided its primary purpose is not fraud or tax advantage.
Question posed: Whether the described operation can qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
If the operation is carried out within the commercial sphere pursuant to Law 3/2009, it would meet the requirements for a total spin-off under Article 76.2.1.a) of the LIS. As the allocation of shares to the partners is proportional, it is not necessary for the assets to constitute business lines. However, the regime will not apply if the primary objective is fraud or tax evasion, or if it lacks valid economic reasons pursuant to Article 89.2 of the LIS.
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