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V0096-23 ·30 January 2023 ·consulta-vinculante Medium impact
Tax

The special spin-off regime cannot be applied if the segregated elements do not constitute an autonomous branch of activity

A query is made as to whether the transfer of three rural properties from an agricultural company can be considered a partial spin-off under the special regime of Corporate Income Tax. The DGT responds that, as there is no differentiated organization of material and human resources for those properties relative to the rest of the activity, the requirement of a branch of activity is not met.

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2023-01-30PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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