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A society aiming to become a SOCIMI proposes a total spin-off to separate residential land from commercial property intended for rental. The DGT examines whether this operation qualifies for the special spin-off regime under Corporate Income Tax.
Question raised 1. Whether the special regime of Chapter VII of Title VII of the Corporate Income Tax Act is applicable to the total demerger operation described.
A total demerger could apply the special regime of the Corporate Income Tax Act if carried out for valid economic reasons, such as the restructuring of activities. However, if the beneficiaries are inactive entities with tax credits, it could be understood that the motive is the exploitation of said credits, lacking a valid economic reason. If the beneficiaries are newly created entities, the operation could be understood as economically valid. The beneficiaries shall subrogate into the transferor's negative tax bases within the legal limits.
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