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A company proposes a partner separation via capital reduction, transferring shares in other companies. It is queried whether positive income from the transferring entity may qualify for corporate income tax exemption.
Question posed: Application of the exemption provided for in Article 21.3 of the Corporate Income Tax Law to the positive income potentially generated in the separation operation for entities X and Y:
The transferring entity may apply the exemption if it meets the minimum participation and holding period requirements, including an indirect participation analysis ('look through') if the entity is a holding company. In the case of venture capital entities, the percentage and seniority requirements are waived. The receiving entity may also apply the exemption based on its direct or indirect participation. To avoid double taxation, the valuation rules and the mechanisms of transitional provision 23 of the Corporate Income Tax Law may be applied.
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