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A parent company has enquired whether a series of reorganisations (contribution of a real estate business line, spin-off of shares, and mergers) may qualify for the special Corporate Income Tax regime. The Directorate-General for Taxes (DGT) has ruled that this is possible provided that the requirements of economic unity, commercial law compliance, and valid economic reasons are met.
Cuestión planteada Si las operaciones descritas pueden acogerse al régimen fiscal previsto en el Capítulo VII del Título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades.
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