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The taxpayer asks whether their operation can apply the special regime for mergers and demergers of the LIS. The DGT indicates that, if the operation is a commercial total demerger and the shareholders receive shares proportionally, the regime could apply, provided that its primary purpose is not fraud or tax advantage.
Question posed: Whether the proposed operation may qualify for the special regime of Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
To apply the special regime, the operation must be a total demerger pursuant to Article 76.2.1º a) of the LIS and Article 69 of Law 3/2009. If the shareholder receives shares proportionally, it is not necessary for the assets to constitute business lines. However, the regime will not apply if the primary objective is tax advantage or evasion, requiring valid economic reasons pursuant to Article 89.2 of the LIS.
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