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A company has requested a ruling regarding an improper partial demerger of a subsidiary to reorganise its activities. The DGT has ruled that the transaction may qualify for the special tax regime if it is classified as a commercial demerger, constitutes autonomous lines of business, and is driven by valid economic motives.
Question raised 1. Whether the described operation may qualify for the special tax regime of Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
The operation may qualify for the special regime if it is carried out under the commercial requirements of demerger and the segregated assets constitute an autonomous economic unit (branch of activity). It is necessary to prove that there is a differentiated organization of material and human resources in both the transferred and the retained parts. Likewise, the operation must not have the primary objective of tax fraud or evasion, but rather valid economic motives. In the event of the subrogation of negative tax bases, these shall be limited by the amount of depreciation that would have been tax-deductible in the acquirer.
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