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A digital content and real estate company has requested a ruling on whether its total demerger qualifies for the special Corporate Tax regime and how VAT, Property Transfer Tax (IIVTNU), and Stamp Duty (ITP/AJD) would be applied. The DGT has determined that the operation meets the requirements for a total demerger and that the stated economic reasons are valid for the special Corporate Tax regime.
Cuestión planteada 1º) Si la operación descrita puede 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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