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The taxpayer inquired whether partial and total demergers could qualify for the special regime under Corporate Income Tax. The DGT ruled that a partial demerger does not meet the requirements if business branches are not transferred, whereas a total demerger may qualify for the regime provided it is carried out for economic reasons rather than solely for tax purposes.
Question raised: Whether the described operations may qualify for the special regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
For a partial spin-off, it is a requirement that the spun-off assets constitute business lines, that is, autonomous economic units with differentiated organizations of material and human resources. In a total spin-off, if the allocation of values to the partners is proportional, it is not necessary for the assets to be business lines. Notwithstanding, the special regime shall not apply if the main objective of the operation is tax fraud or evasion, or if it lacks valid economic reasons.
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