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The applicant asks whether their total demerger operation can qualify for the special regime under Corporate Income Tax. The DGT indicates that if the operation complies with commercial regulations and the requirements of the LIS, it could be applicable, provided its primary purpose is not tax evasion or tax advantage.
Question raised - Whether the special regime regulated in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax, is applicable to the proposed total demerger operation.
To benefit from the special regime for total demergers, the operation must comply with Article 76.2.1º a) of the LIS and be carried out under Article 69 of Law 3/2009. If the partners receive shares in proportion to their previous holding, it is not necessary for the assets to constitute business lines. However, pursuant to Article 89.2 of the LIS, the regime shall not apply if the main purpose of the operation is tax fraud or evasion, or if it lacks valid economic reasons.
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