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A family-owned entity has enquired whether it can apply the special Corporate Tax regime for a share exchange and a total demerger. The DGT has ruled that this is possible provided that all legal requirements are satisfied and the primary purpose of the transaction is not tax evasion or obtaining a tax advantage.
Question posed: Whether the special tax regime of Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax is applicable to the transactions proposed.
For the share exchange, the beneficiary entity must acquire the majority of voting rights and comply with the requirements of Article 80 of the LIS. In a total demerger, if it is proportional, it is not necessary for the segregated assets to be business branches. In both cases, the transaction must respond to valid economic reasons and not to a mere purpose of obtaining a tax advantage, pursuant to Article 89.2 of the LIS.
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